ML20077D457

Licensee Contractor and Vendor Inspection Status Report. Quarterly Report,January-March 1991.(White Book)

ML20077D457
Person / Time
Issue date:	05/31/1991
From:	Office of Nuclear Reactor Regulation
To:
References
NUREG-0040, NUREG-0040-V15-N01, NUREG-40, NUREG-40-V15-N1, NUDOCS 9105300232
Download: ML20077D457 (105)

Text

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NU R EG-0040 Vol.15, No.1 b

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. Licensee Contractor anc Vencor Inspection i

Status Reaort Quarterly Report January-March 1991

__ _ __ _._ _z U.S. Nuclear Regulatory Commission i

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Available from Superintendent of Documents l

U.S. Government Painting Office Post Office Box 37082 Washington, D.C. 20013 7082 A year's subscription consists of 41ssues for this publication.

Single copies of this publication are available from National Technical information Service, Springfield, VA 22161 Y

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I NURIIG-0040 Vol.15, No.1 t

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Licensee Contractor and Vendor Inspection Status Report 2

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Quarterly Report January-March 1991 Manuweript Completed: April 1991 j

Date Putlished: May 1991 I

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Division of Reactor Inspection and Safeguards Omce of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555

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ABSTRACT This periodical covers the results of inspections I ionned by the liRC's Vendet Inspection Branch that have been distributed to the inspected organization during the teriod frorn January IW1 through March 1991.

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1 TABLE Of CONTENTS PAGE Abstract.....................................................

111 Preface......................................................

vii Reporting fortnat.............................................

-ix Index........................................................

xi inspection Reports...........................................

1 Selected Bulletins and Infortnation kotices Concerning Adequacy of Vendor Audits and Quality Of Vendor Products.....

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Vendor Inspections Related to Reactor Sites..................

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PREFACE A fundamental premise of the Nuclear Regulatory Connission (NRC) licensing and insrection program is that licensees are responsible for the proper construc-tion and safe and efficient operation of their nuclear power plants.

The total governnent-industry system for the inspection of connercial nuclear f acilities has been designed to provide for multiple levels of inspection and verifica-tion.

Licensees, contractors, and vendors each participate in a quality verification process in con.pliance with requirements prescribed by the NRC's rules and regulations (Title 10 Code of Federal Regulations).

The NRC performs an overview of the concercial nuclear industry by inspection to determine whether its requirenents are being met by licensees and their contractors, while the major inspection effort is performed by the industry within the framework of ongoing quality verification programs.

The licensee is responsibit for developing and maintaining a detailed quality assuronce (QA) plan with iaplementing procedures pursuant to 10 CFR 50 Through a system of-planned and periodic audits and inspections, the licensee is respcosible for assuring that suppliers, contractors and vendors also have suitable and appropriate quality programs that meet NRC requirenents, guides, codes and standards.

The Vendor Inspection Branch (Vib) reviews and inspects nuclear steam system suppliers (NSSSs), architect engineering (AE) firms, suppliers of products and services, independent testing laboratories performing equipment qualification tests, and holders of NRC licenses (construction permit holders and operating licenses) in vendor-related areas.

These inspections are performed to assure that the root causes of reported vendor-related problems are determined and appropriate corrective actions are developed.

The inspections also review the vendors' conformance with applicable NRC and industry quality requirements, the adequacy of licensees' oversight of their vendors, and that adequate interfaces exist between licensees and vendors.

The VIB inspection emphasis is placed on the quality and suitability of vendor products, licensee-vendor interf ace, environmental qualification of equipment, and review of equipment problems found during operation and their corrective action.

When nonconformances with NRC requirements and regulations are found, the inspected organization is requireo to take appropriate corrective action and to institute preventive measures to preclude recurrence.

When generic implications are identified, NRC assures that affected licensees are inf ormed through vendor reporting or by NRC generic correspondence such as information notices and bulletins, vii

The White 000k is published quarterly and contains copies of all vendor inspection reports issued during the calendar quarter for which it is published.

Each vendor inspection report lists the nuclear f acilitics to which the results are applicable thereby informing licensees and vendors of potential probleras.

In addition, the affected Regional Offices are notified of any significant problem areas that may require special attention.

The White Book also contains a list of selected bulletins and information notices involving vendor issues.

Correspondence with contractors ard vendors relative to inspection dsta contained in the White Book is placed in the USNRC Public Document Room, located in Washington, D.C.

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ORGANIZATION: COMPANY DIVISION CITY, STATE REPORT INSPECTION INSPECTION NO.:

Docket / Year / Sequence DATE:

DN-SITE HOURL CORRESPONDENCE ADDRESS: Corporate Name Division ATTN:

Name/ Title Address City, State Zip Code ORGANIZATIONAL CONTACT:

Name/ Title TELEPHONE NtWBER:

Teleobone Number NUCLEAR INDUSTRY ACTIVITY: Description of type of components, equipment, or services supplied ASSIGNED INSPECTOR:

Eme/ Vendor Inspection Branch Section DIte

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OTHER INSPECTOR (S):

Name/ Vendor Inspection Branch Section APPROVED BY:

Hare / Chief - Section/ Vendor Inspection Branch

'Ila G INSPECTION BASES AND SCOPE:

A.

BASES:

Pertain to the inspection criteria that are applicable to the activity being inspected; i.e., 10 CFR Part 21, Appendix 0 to 10 CFR Part 50 and Safety Analysis Report or Topical Report commitments.

B.

SCOPE: Sunnarizes the specific areas that were reviewed, and/or identi-TTes~ plant systems, equipment or specific components that were inspected, for reactive (identified problem) inspections, the-scope summarizes the problem that caused the inspection to be performed.

PLANT SITE APPLICABILITY: List plant name and docket numbers of licensed facilities for which equipment, services, or records were examined during the inspection.

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ORGANIZATION: ORCANIZATION CITY, STATE REPORT INSPECTION NO.:

RFSulTS:

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A.

VIOLATIONS:

Shown here are any inspection results determined to be in violation of Federal Regulations (such as 10 CFR Part 21) that are applicable to the organization being inspected.

B.

HONCONFORMANCES:

Shown here are any inspection results determined to be in nonconformance with applicable commitments to NRC requirements, in addition to identifying the applicable NRC requirenents, the specific industry codes and standards, company QA manual sections,- or operating procedures which are used to implement these commitments may be referenced.

C.

UNRESOLVED ITEMS: Shown here are inspection results about which more information is required in order to determine whether they are acceptable items or whether a violation or nonconformance may exist.

Such-items will be resolved during subsequent inspections.

D.

STATUS OF PREVIOUS INSPECTION FINDINGS:

This section is used to identify the status of previously identified violations, items of nonconformance, and/or unresolved items until they are closed by appropriate action.

For all such items, and if closed, include a brief statement concerning action which closed the item.

If this section is omitted, all previous inspection findings have been closed.

E.

INSPECTION FINDINGS AND OTHER COMMENTS: This section is used to provide significant information concerning the inspection areas identified under " Inspection Scope." Included are such items as mitigating circumstances concerning a violation or nonconformance, or statements concerning the limitations or depth of inspection (sample size, type of review performed and special circumstances or concerns identified for possible followup).

For reactive inspections, this section will be used to summarize the disposition or status of the condition of event which caused the inspection to be performed.

F.

PERSONS CONTACTED:

Typed, Nane, Title

• present during exit meeting I

SAMPLE PAGE (EXPLANATION OF FORMAT AND TERMINOLOGY) l 1

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INDEX FACILITY REPORT NUMQEB PAGE Anchor / Darling Enterprises, Inc.

99901115/90-01 1

Laconia, New Hampshire Anchor / Darling Valve Company 99900053/90-01 la Williamsport, Pennsylvania GE Apparatus Servico Shop 99901024/09-01 32 Chamblee, Georgia GE Supply Company 99901112/80-01 30 Elmhurst, Illinois GE Supply Company 99901123/08-01 42 El Monte, California GE Supply Company 99901124/00-01 46 Garden Grove, California Performance Contracting, Inc.

99901200/90 SO Shawnee Mission, Kansas Radnor Alloys, Inc.

99901217/90-01 56 Wayne, Pennsylvania ROMAC Supply Company 99901143/80-01 60 Commerce, California Southern Mechanical Seals, Inc.

99901215/91-01 73 Miramar, Florida l

Voyten Electric and Electronics 99901131/00-01 77 l

Franklin, Pennsylvania l

l WESCO 99901109/88-01 81 l

Augusta, Maine I

WESCO 99901132/88-01 86 Murraysville, Pennsylvania x1

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February 14, INI e

Docket No. 99901115/90-01 Mr. Peter B. Ellis, General Manager Anchor / Darling Enterprises, Incorporated 32 Moulton Street Laconia, New Hampshire 03245

Dear Mr. Ellis:

This letter addresses the inspection of your facility at Laconia, New Hampshire, conducted by Messrs. Robert L. Pettis and Stewart L. Magruder of the Vendor Inspection Branch on September 17 through 10 1990 and the discussion of our findings with you and other members of your, staff at the conclusion of the inspection.

The inspection was conducted primarily to review Anchor / Darling EnterpMses' (A/DE's) (formerly Anchor / Darling Industries, Hatfield, Pennsylvania) response and implementation of corrective actions to previously identified nonconformances.

In addition, a review of A/DE's present operations includ-ing vendor audits, implementation of 10 CFR Part 21, and qualification testing of the mechanical shock suppressor (snubber) product line was also performed.

The inspectors noted that since the last inspection-of Anchor / Darling Industries in August 1988, A/DE has developed a 10 CFR 50, Appendix B, QA manual specif-ically for ASME Code exempt parts and a commercial-grade dedication arogram which includes a total reclassification of replacement parts for bot 1 the mechanical and hydraulic snubber product line.

These programs were not in place during the 1988 inspection and were the subject cf several nonconformances. As a result. NRC Information Notice No. 88-95 was issued.

An implementation review of A/DE's commercial-grade dedication program was not performed during this inspection.

The inspectors determined that the implementation of your Quality Assurance (QA) program failed to meet certain NRC requirements, specifically the lack of documentation necessary to support qualification by -load rating of your AD-12500 Series dyna / Damp mechanical snubber which is cerJfied to the 1980 Edition of the ASME Code.

The inspectors also determined that since 1983 approximately 100 units have been manufactured by A/DE and supplied to the nuclear industry.

However, A/DE stated that these snubbers were supplied to the 1977 ASME Code, or earlier editions, which recognize qualification by analysis not load rating.

It is our understanding that A/DE has analytical calculations available to support the load carrying capacity of the AD-12500 model snubber.

We acknowledge the receipt of your letter, dated September 26, 1990, wherein you conrnitted to performing a total requalification of-the AD-12500 model snubber utilizing the load rating approach required in the 1980 Edition.of ASME 111, Subsection NF, Article NF-3260. This requalification is tentatively scheduled for completion by April 1991.

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Peter B. Ellis The inspectors also identified that spring rate information published in the A/DE catalog for your mechanical snubber product line does not have a documented basis and that A/DE failed to conduct audits or Provide for other means of assurance to verify that safety related suppliers 1olding Quality Systems Certificates issued by ASME are effectively implementing their QA programs as required by 10 CFR Part 50, Appendix B.

In response to the enclosed Notice of Nunconformance, please provide us within 30 days from the date of this letter, a written statement containing: (1)a description of the steps that have been or will be taken to correct these items; (2) a description of the steps that have been or will be taken to prevent recurrence; and (3) the dates that your corrective action and preventive measures were or will be completed. We will consider extending the response time if you can show good cause for us to do so.

Your response should also include a plan for addressing the possible inadvertent use of safety-related material associated with nonconformance 88 01-04 ident. Ned during our August 1988 inspection of the Hatfield facility.

A/DE's correcth action to this item was reviewed during our Laconia inspection and resulted in unresolved item 90-01-04.

You are requested to evaluate this matter under your 10 CFR Part 21 program and inform us of the status.

The responses requested by this letter are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.

In accordance with 10 CFR 2.790 cf the Connission's regulations, a copy of the letter and the enclosed inspection report will be placed in the NRC's Public Document Room.

Should you have any questions concerning the inspection, we would be pleased to discuss them with you.

Sincerely

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e Leif J. Norrholm, Acting Chief Vendor Inspection Branch Division of Reactor Inspection and Safeguards Office of Nuclear Reactor Regulation

Enclosures:

1.

Appendix A - Notice of Nonconformance 2.

Appendix B - Inspection Report No. 99901115/90-01 2

APPENDIX A Anchor / Darling Enterprises, Incorporated Docket No. 99901115/90-01 NOTICE OF NONCONFORMANCE Based on the results of an NRC inspection conducted on September 17 through September 20, 1990 at the Laconia, New Hampshire facility of Anchor / Darling Enterprises, Incorporated (A/DE), it appears that certain activities were not conducted in accordance with NRC requirements.

1.

Criterion XVill of Appendix B to 10 CFR Part 50, " Audits," states, in part:

"A comprehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the quality assurance program and to determine the effectiveness of the program.... Audit results shall be documented....

Followup action, including reaudit of deficient areas, shall be taken where indicated."

Contrary to the above, Section 5.5.1, Subcontracted Services and Material," of A/DE Quality Assurance Manual (QAM) (10 CFR 50, Appendix B, ANS1 N45.2) Revision 1, dated February 6, 1990, does not require program implementation audits or alternate measures for verifying that suppliers of safety-related material holding Quality Systems Certificates issued by the ASME are effectively implementing the approved QA programs.

2.

Criterion 111 of Appendix B to 10 CFR Part 50, " Design Control," states, in part, that where a test program is used to verify the adequacy of a specific design feature, a prototype unit shall be qualification tested under the most adverse design conditions.

Article NCA-3551.2, " Load Capacity Data Sheet (LCDS)," cf Subsection NCA to the 1980 Edition of Section !!! to the ASME code states, in part, that the LCDS is the design document to be used when the component support is designed using the load rating method.

Article NF-3261, " Procedure for Load Rating," of Subsection NF to the 1980 Edition of Section 111 to the ASME Code states, in part, that the procedure for load rating shall consist of imposing a total load on one or more duplicate, full size samples of a component support.

Contrary to the above, A/DE was unable to provide to the NRC inspectors documentation to support qualification, by load rating, of the Model AD-12500 mechanical snubber which is certified to the 1980 Edition of the ASME Code. Additionally, A/DE was also unable to provide documen-tation to support spring rate data for their entire mechanical shock suppressor product line as published in their catalog.

3

Anchor / Darling Enterprises, incorporated Docket No. 99901115/90-01 Page 2 3.

Criterion XV:1 of Appendix B to 10 CFR Part 50, " Quality Assurance Records," states, in part, that sufficient records be maintained to furnish evidence of activities affecting quality.

Such records shall include data such as qualifications of personnel, procedures, and equipment.

Section 9.1 of A/DE Product Specification No. EN-DS-01, " Documentation,"

states, "See Anchor / Darling Procedure MSTS-0001, " Mechanical Snubber Development Program, " Paragraph 9.0 for requirements".

Section 9.2.4 requires a calibration records reference for all instrumentation used".

Contr* y to the above, A/DE could not produce calibration records for equipment used to qualification test the AD-5500 and AD-12E90 model mechanical snubber during the July 1981 and January 1982 test periods.

Calibration ecords reviewed dated back only to February 1982.

Addi-t '- 'lly, A/DE could not produce documentation to verify the basis of w' (vane tharts used to verify snubber operability in the field using in-pi" % testing methods.

Dated at Rockville, Maryland this 14th day of February,1991 4

ORGANIZATION: ANCH0R/ DARLING ENTERPRISES, INCORPORATED LACONIA, NEW HAMPSHIRE REPORT INSPECTION INSPECTION N0.: 99901115/90-01 DATE:

September 17-20, 1990 ON-SITE HOURS:

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CORRESPONDENCE ADDRESS: Mr. Peter B. Ellis General Manager Anchor / Darling Enterprises, Incorporated 32 Moulton Street Laconia, New Hampshire 03246 ORGANIZATIONAL CONTACT: Jean Keyes-Stewort, Quality Assurance Manager TELEPHONE NUMBER:

(603) 528-1931 l

NUCLEAR INDUSTRY ACTIVITY:

Designer and manufacturer of dyna / Damp mechanical and hydraulic shock suppressors used throughout the nuclear power industry.

Anchor / Darling Enterprises (formerly Anchor / Darling Industries, Hatfield, Pennsylvania) also holds a Quality System Certificate as a Material Supplier issued by the American Society of Mechanical Engineers.

A E[I.. PEtT1 s, J r., M'Reaitlve~nsp[ectionSection b

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ASSIGNED INSPECTOR:

Date No. 1 (RIS-1) Vendor Inspection Branch (V!B)

OTHER INSPECTOR (S):

S. L. Magruder, Special Pro.iects Section, VIB D. L. Jew, NRC Consultant, EAS Energy Services h

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APPROVED BY:

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-Qf-U~T6tapovs, Chiet, RIS-1, VlB Date INSPECTION BASES AND SCOPE:

A.

BASES:

10 CFR Part 21; 10 CFR Part 50, Appendix B and ASME 111 Subsection NCA, Article NCA-3 BOO.

D.

SCOPE:

The inspection was performed primarily to review Anchor / Darling's response to previous nonconformancu identified during NRC Inspection No. 99901115/88-01, dateo December 16,1988.

PLANT SITE APPLICABILITY: Arkansas Nuclear One 1 and 2 (50-313, 50-368);

Diablo Canyon 1 and 2 (50-275, 50-323); Vogtle 1 and 2 (50-424, 50-425);

South Texas 1 and 2 (50-498, 50-499); Surry 1 and 2 (50-280, 50-281).

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ORGANIZATION: ANCHOR / DARLING ENTERPRISES, INCORPORATED LACONIA, NEW HAMPSHIRE REPORT INSPECTION NO.: 99901115/90-01 RESULTS:

PAGE 2 of 13 A.

VIOLATIONS:

There were no violations identified du-ing the inspection.

B.

NONCONFORMANCES:

1.

Contrary to the requirement of Criterion XVill, " Audits," of Appendix B to 10 CFR Fart 50, Anchor / Darling Enterprises, Incorporated (A/DE) does not require program implementation audits of material manufacturers and/or material suppliers holding a Quality Systems Certificate (QSC) issued by the American Society of Mechanical Engineers (ASME).

(90-01-01) 2.

Contrary to the requirements of Criterion 111. " Design Control,"

of Appendix B to 10 CFR Part 50; Article NCA-3551.2, " Load Capacity Data Sheet" (LCDS) and Article NF-3261, " Procedure for Load Rating," of Subsections NCA and NF, respectively, to the 1980 Edition of Section 111 to the ASME Code, A/DE was unable to provide load rating documentation necessary to support the qualification and design basis of their Model AD-12500 mechanical shock suppressor.

Additionally, A/DE was also unable to provide documentat h to support spring rate data for their entire mechanical awek suppressor product line as published in the A/DE catalog.

(90-01-02) 3, htrary w the requirements of Criterion XVil, " Quality Assurance Recordt," of Appendix B to 10 CFR Part 50 and A/DE Procedure V,.M OG., " Mechanical Snubber Development Program," A/DE could

.ot produce calibration records for equipment used to qualification test the AD-5500 and AD-12500 model mechanical snubber during the July 1981 and January 1982, test periods, respectively. Addition-ally, A/DE could not produce documentation to verify the basis of acceptance charts used to verify snubber operability in the field using in-place testing methods.

(90-01-03)

C.

UNRESOLVED ITEMS:

During the review of Anchor / Darling Industries' (A/Dl's) corrective action to previous nonconformance 88-01-04, A/Dl's disposition for severalMaterialRejectionNotices(MRNs),whichremained" ogen"for several years without the affected material placed "on-hold, is inadequate to assure that the affected material was not inadvertently used.

(90-01-04) 6

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ORGANIZATION:

ANCHOR / DARLING ENTERPRISES, INCORPORATED LACONIA, NEW HAMPSHIRE REPORT INSPECTION NO.: 99901115/90-01 RESULTS:

PAGE 3 of 13 D.

STATUS OF PREVIOUS INSPECTION FINDINGS:

1.

(Closed) Violation (88-01-01)

Contrary to Section 21.31 of 10 CFR Part 21, Anchor / Darling Industries purchase orders (P0s) to vendors for safety-related components and services, up through early 1988, failed to specify the prov sions of 10 CFR Part 21. Several P0s reviewed during the 1988 time frame, however, did invoke 10 CFR Part 21, but only on a limited basis.

The NRC inspectors selected several safety-related P0s for review to determine A/Dl's compliance.

The P0s included J. T. Ryerson (May21,1990); GE Silicone Products (June 11,1990); Bearings, Incor 31,1990); Lindberg Heat Treating (July 24, 1990)porated (Mayand A.E.L. Laboratories (August 2, 1990).

In all cases, the provisions of 10 CFR Part 21 were invoked on each supplier.

Violation 88-01-01 is considered closed.

2.

(Closed) Nonconformance (88-01-04)

Contrary to Sections 7.3 and 9.3 of the A/DI Quality Assurance (QA) manual, approximately 68 MRNs covering potentially defective material during the period 1981 to present, remain "0 PEN" and the affected material cannot be located.

t The NRC inspector reviewed 55 MRNs relating to snubbers provided to the nuclear industry by A/DI to determine if adequate corrective action had been performed. The remaining 13 MRNs (out of the 68 identified during the August 1988 inspection) l-could not be located by A/DI, and therefore were not reviewed l

during the inspection.

A/01 stated that these MRNs related only-to the valve actuator product line which was manufactured by A/01 prior to October 10, 1980. A/D1's first shipment of snubbers to the nuclear industry began in February 1981.

The approach utilized by A/D1 to disposition the-affected material associated with the MRNs initiated during the 1983 timeframe was to reconvene the Material Review Board (MRB) in 1988 and provide a reasonable disposition based on present information available and, in some. cases, records obtained during the 1983 timeframe. The NRC review of this documentation indicated that for most cases documentation was unavailable to support the MRB's disposition. For example, MRNs which noted the disposition "Use As-Is", " Scrap" or " Return to Vendor" did 7

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ORGANIZATION: ANCHOR / DARLING ENTERPRISES, INCORPORATED-LACONIA, NEW HAMPSHIRE

-REPORT INSPECTION NO.: -99901115/90-01 RESULTS:-

PAGE 4 of 13 o

not contain documentation, other'than the MRB's written statement, to support the basis for the disposition.

The NRC inspectors expressed concern over the MRBs method of i

dispositioning the affected material. A/DE representatives stated that they received such material directly from A/DI (Hatfield).during the move to Laconia and were not responsible for the content nor were they familiar with the issue.

Despite the lack of documentation provided by A/01 to support the disposition of the MRNs, the extent to which material was rejected primarily involved discrepancies within the machining process which may have led to tolerance related problems. Most of the dispositions involved the statement "0K, Use As-Is" with some additional work to be performed-by A/DI during the assembly process.

Tolerance related problems in active components such as the Ball Screw, Verge and Rack would have normally been identi-fied during the functional test phase performed by A/DI prior to' shipment of the snubber.

However, other discrepancies noted were of a material defect nature (linear indications, cracked housings,etc.). The following is a list of several MRNs reviewed during the inspection for which documentation was unavailable to adequately support implementation of the MRB's disposition. The deficiency indentified on the MRN appears to have the potential to cause a possible reduction in.the load

(

carrying capacity of the snubber. Additionally, such a deficiency l

may'not be detected during normal functional or routine naintenance

~ testing of the snubber in the field.

-MRN DATE DATE DEFICIENCY DISPOSITION

.NO.

OPENED CLOSED IDENTIFIED OF THE MRB

'1316 7/82 9/88-Undercut welds in Use As-Is Transition Tube 1478 3/83 9/88 Failed Tensile Test Returned to for 6-inch Tube Vendor 1523 6/83 9/88 Linear Indications Scrap on Rear Housing

_ Material 1657 10/83 9/88 No Heat Number Use For Etched on Cap Non-Nuclear 1906 10/84 10/88 Crack observed in Scrap 24-inch Pipe Clamp Material L

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ORGANIZATION:

ANCHOR / DARLING ENTERPRISES, INCORPORATED LACONIA, NEW HAMPSHIRE REPORT INSPECTION N0.: 99901115/90-01 RESULTS:

PAGE 5 of 13 Unresolved item 90-01-04 was identified during this part of the inspection.

E.

INSPECTION FINDINGS AND OTHER COMMENTS:

===1.

Background===

The last inspection performed at A/DI was conducted in August 1988 at Hatfield, Pennsylvania. Since then, A/01 has undergone substential changes including relocating to Laconia, New Hampshire.

The changes began in the early 1980's when A/D1 bought an interest in the Bergen-Paterson Pipesupport Corporation (B-P), a manuf acturer of hydraulic snubbers and component supports.

Late in December 1987, Anchor / Darling management decided that A/DI and B-P should separote and that A/DI would take over B-P's facilities in Laconia as well as their snubber product line. A/Dl's intentions at this point were to move the product line to Hatfield within 18 months.

For the first eight months of 1988, A/01 had only two employees in Laconia both of whom were former B-P employees.

The former head of snubber testing was designated as Facilities Manager and the former head of manuf acturing was designated his assistant.

Basically, business went on as usual for B-P as they continued to process orders for hydraulic snubbers. A/DI essentially took parts manufactured or bought by B-P (under the B-P quality assurance program) assembled them and sold them back to B-P who then shipped them under the B-P name.

This continued until June of 1988 when A/DI issued B-P a QA manual to work under. At this time, paperwork was processed through the Hatfield office instead of relying on B-P, who was also significantly reducing their workforce during this period.

During the summer of 1988, A/01 purchased a small machine shop that had been doing work for them and integrated them into the B-P facility. A/01 alsa hired a QA assistant in August 1988 to implement their QA program. During the time of the NRC inspection at Hatfield, mechanical snubbers were being manufactured in Hatfield while the hydraulic line was being manufactured in Laconia.

In December 1988, A/DI reversed its earlier decision and moved the entire snubber line to Laconia.

Additionally, instead of moving the Hatfield employees to Laconia, it was decided to staff the Laconia plant with former B-P personnel.

A/D1 also received permission from ASME to transfer their QSC from Hatfield to 9

ORGANIZATION:

ANCHOR / DARLING ENTERPRISES, INCORPORATED LACONIA, NEW HAMPSHIRE REPORT INSPECTION N0.:

99901115/90-01 RESULTS:

PAGE 6 of 13 Laconia in May 1989, and during the summer A/D1 transferred all their inventory to Laconia.

In July 1989, the Hatfield facility was officially terminated and th. name of the Laconia facility changed to Anchor / Darling Enterprises, Incorporated. A/DE successfully passed an ASME audit in July 1990.

As a result, their QSC has been extended through August 31, 1993.

2.

Qualification of the Dyna / Damp Mechenic-' em iber Product Line The qualification of the dyna / Damp la anubber product line was reviewed during the inspect product line ee.,ign loads of includes seven snubber sizes ranging 400-125,000 pounds ':cmmor.ly referred t' as 0.40-125 kips).

The review involved determining the technii J adequacy of Product Specification No. EN-DS-01, " Mechanical Snubber Design Specifi-cation," Revision F, dated April 1990, and the conformance of the actual snubber qualification to the product specification.

Revision F of the specification contains minimal technical changes since its initial issuance in January 1981.

The functional and engineering requirements established by this specification appeared to be technically adequate to qualify the mechanical snubber product line. However, upon reviewing the qualification of the 125 kip snubber (Model AD-12500), the NRC inspectors noted that the documentation available did not substantiate qualification of this unit per the product specification for the following reasons:

a.

Section 5.2 of Product Specification No. EN-DS-01 states

-that, " snubber rated-loads be established by load rating in accordance with ASME 111, Subsection NF-3260."

Additionally, this load rating test shall be performed in i

accordance with A/01 Load Rating Test Procedure MSTS-007.

For the AD-12500 model snubber, documentation was unavail-able to support the load rating basis according to NF-3260.

b.

Section 8.1 of Product Specification No. EN-DS-01 states that, " qualification testing shall be performed on a minimum of two units of each size in accordance with Anchor / Darling Procedure MSTS-005, " Snubber Qualification Test."

For the AD-12500 snubber, qualification testing was performed per Anchor / Darling Procedure MSTS-003,'" Engineering Evaluation Testing" and was done on only one unit. The major differ-rences between procedures MSTS-003 and -005 are that MSTS-005 requires the testing-of two units (as opposed to one unit per MSTS-003) and MSTS-005 requires that qualification tests be performed on spring rate, displacement, velocity, and drag force at elevated temperatures (205 degrees F) as well 10

ORGANIZATION: ANCHOR / DARLING ENTERPRISES, INCORPORATED LACONIA, NEW HAMPSHIRE REPORT INSPECTION NO.: 99901115/90-01 RESULTS:

PAGE 7 of 13 as at ambient temperatures.

Procedure MSTS-003 only requires that these tests be performed at ambient temperatures.

During the inspection, it was determined that Vogtle, South Texas Project, Diablo Canyon and Arkansa3 were the only re-cipients of the AD-12500 model and that such units may have been furnished by A/DE under the 1977 Edition of the ASME Code which allowed qualification to be performed by analysis.

However, such units were certified to the 1980 Edition which only recognizes load rating. A/DE stated that a 10 CFR Part 21 report was not required since analytical calculations performed previously demonstrate the load carrying capacity of the AD-12500 model.

In a letter dated September 26, 1990, A/DE committed to perform a requalification test using the load rating method which is required in the 1980 Edition of ASME Ill, Subsection NF-3260.

Such tests are scheduled for completion by April 1991. A complete review of A/DE's calcu-lations used to support their basis for not issuing a 10 CFR Part 21 report will be reviewed during our next inspection.

Nonconforuance 90-01-02 was identified during this part of the inspection.

3.

Calibration of Test Instrumentation Section 9.1 of Product Specification No. EN-DS-01, "Documenta-tion" states, "See Anchor / Darling Procedure MSTS-0001,

' Mechanical Snubber Development Program', Paragraph 9.0 for requirements." Section 9.2.4 of Procedure MSTS-001 requires a

" calibration records reference for all instrumentation used."

A/DE stated that the qualification tests for the AD-5500 Model (55 kip) and AD-12500 Model (125 kip) were performed in July 1981 and January 1982, respectively, by New Hampshire Testing Laborotory, a subsidiary of B-P.

However, calibration records for the Wavetek Funct. ion Generator and the PRC Humitemp (Model B, Serial No. 809), which were two instruments used in the qualifica-tion test of these two snubbers, could not be produced by A/DE during the inspection. The Wavetek Function Generator had cali-bration records which dated back to March 1982, while the PRC Humitemp had records which dated back to February 1982.

Non-conformance 90-01-03 was identified during this part of the inspection.

4.

Spring Rate Data The 1982 dyna / Damp Mechanical Snubber catalog, which was published 11

~

ORGANIZATION: ANCHOR /DARLlHG ENTfRPRISES, INCORPORATED LACONIA, NEW :W PShikE REPORT iMSPECTION NO.:

99901115/90-01 RESULTS:

PAGE 8 of 13 when A/D1 was located in Kulpsville, Pennsylvania, and the most recent edition, which lists their corporate office in Rosemont, Pennsylvania, contain spring rates for the mechanical snubber line.

Section 5.6 of Product Specification EN-DS-01 requires that spring rates be established by test by subjecting test specimens to cyclic loading between 3 and 33 c Further-more, peak-to-peak displacement (ycles per second (CPS).one cycle) shall inches measured pin-to-pin at frequencies of 9 and 18 CPS. No correlation could be made between the published spring rate values and those attained by testing per the product specification.

More specifically, for the Model AD-5500 unit, the 1982 catalog lists the average dynamic spring rate as 150,000 pounds per inch while in 'the 10 - 33 CPS range. When qualifying this unit per MSTS-005, however, the maximum tested dynamic spring rate was i

only 124,000 pounds per inch which is 21% lower than the published value.

Likewise, for the Model AD-12500 unit in the 10 - 33 CPS range, the published spring rate was 1,600,000 pounds per inch while the maximum tested dynamic spring rate was only 1,100,000 pounds per inch, or 45% below the published value.

These deviations could not be evaluated since A/DI could not produce documentation to support the basis for the published spring rates.

Nonconformance 90-01-02 was identified during this part of the inspection.

5.

In-Place Snubber Testing Machine l

A/DE has-designed a machine to test snubbers in-place which consists of a solid-state control console, an electric drive head, and adapters which allow for testing of the complete l

mechanical snubber line. The unit is designed to check for the i

drag and velocity of the snubber in-place. Verification of drag l

and velocity is performed by recording resistance torque and-plotting these values on a corresponding acceptance. chart which 1

I then determines the operability status of the snubber based on the values plotted.

A/DE could not produce documentation to verify the basis of the acceptance charts.

F. urthermore, upon performing some experi-mental tests with the unit, A/DE realized the acceptance charts could possibly yield erroneous results depending on certain factors such as snubber orientation.

Subsequently, A/DE informed Houston Light & Power not to use the test unit on the AD-40, 12 l

(

ORGANIZATION: ANCHOR / DARLING ENTERPRISES, INCORPORATED LACONIA, NEW HAMPSHIRE REPORT INSPECTION NO.: 99901115/90-01 RESULTS:

PAGE 9 of 13 AD-70, AD-150, AD-500, and, by additional testing, regenerated more accurcte curves for the acceptance chart for the AD-1600 and AD-5500 models.

A/DE determined that one other unit was sold to Pacific Gas & Electric (PG&E) for the Diablo Canyon nuclear plant. A/DE stated that to their knowledge, PG&E has never used their unit. A more accurate curve for the acceptance chart for the AD-12500 model will be generated in the near future. Noncon-formance 90-01-03 was identified during this part of the inspection.

6.

Analysis of the AD-12500 Model Snubber A hand calculation analyzing the critical members in the load path (compression and tension) of the AD-12500 unit was performed by A/DE. The calculation used a design load of 125 kips and the allowable stresses from ASME Ill, Appendix XVil. The analysis demunstrated that the critical load carrying members were satis-f actory with respect to allowable stress. However, the calculation did not account for the comprtssion stress on the rollers and the thrust race. A/DE stated that these items were probably considered exempt under ASME 111, Subsection NF-2121 and, therefore, not in-cluded in the stress analysis.

This approach is unacceptable since the Code (NF-2121) only exempts such items from material considerations.

However, if such items fall inside the load path of the snubber, their effect should be analyzed with respect to the total load carrying capacity of the snubber.

It should be noted that the Load Capacity Data Sheets (LCDS) for the mechanical snubber line are only qualified to the ASME III 1980 Edition, Summer of 1981 Addenda. Additionally, paragraph NCA-3551.2 states that a LCDS is the design document used when the component support is designed by load rating.

Therefore, A/DE's analysis cannot be used to support the qualification basis for the AD-12500 model mechanical snubber.

This item was discussed previously in Section E.2 of the report.

7.

Review of A/DE's Approved Vendor List The inspectors reviewed A/DE's Approved Vendor List (AVL) and procedures for controlling vendors. Section 5.5.1 of the A/DE QA manual titled, " Subcontracted Services and Material" provides procedures to guide personnel in classifying and qualifying ven-dors.

These procedures require all vendors to be audited by a qualified auditor in accardance with Quality Assurance Standard QA-AU-2, " Quality Assurance Evaluation of Vendors" and QA-AU-3, I

13

ORGANIZATION: ANCHOR / DARLING ENTERPRISES, INCORPORATED LACONIA, NEW HAMPSHIRE REPORT INSPECTION NO.:

99901115/90-01 RESULTS:

PAGE 10 of 13

" Qualification of Audit Persunnel." A/DE uses a five category system to rate vendors upon audit.

However, Section 5.5.1 also considers this audit responsibility to have been met if the Material Manufacturer or Material Supplier holds a valid QSC issued by ASME covering the materials or services to be supplied.

This practice does not verify that the supplier is effectively implementing its QA approved program.

Licensees and their subcontractors are responsible for ensuring that the supplier is effectively implementing their approved QA program as discussed in NRC Information Notice 86-21, issued March 31,1986 and Supplement 1, issued December 4, 1986. Nonconformance 90-01-01 was identified during this part of the inspection.

The AVL currently contains 73 vendors and is broken up into the following categor es:

Calibration, Gear Cutting, Heat Treating, Machining, Material Manufacturer, Material Supplier, Nondestruc-tive examination (NDE) Services, Surface Finishing, Testing, 10 CFR 50/ ANSI N45.2 Procurements and Commercial Grade Items.

These categories are designated for ASME Section 111 and 10 CFR Part 50, Appendix B related work.

The AVL appears to be well maintained and ut:11 zed. All P0s for safety-related items must be placed with vendors who are on the AVL.

The inspectors concluded that A/DE has established acceptable procedures for categorizing and controlling vendors.

8.

Review of A/DE's Supplier Audits The inspectors reviewed the procedures for ptrforming audits of vendors and also reviewed several examples of audits performed to verify implementation.

Section 5.5.1.1 of the A/DE QA Manual titled " Vendor Audits" provides guidance to personnel for conducting audits. This procedure directs that audits be performed on a triennial basis and that approved checklists be used. The following vendors providing services such as heat treating, machining and NDE were selected for review:

Precision Heat Treatment; Unique Machine Company; Valley Enterprises; Universal Testing and Briggs Associates.

The NRC inspectors determined that the audits reviewed appeared thorough and well documented and that the vendors appeared qualified to provide the services contracted for by A/DE.

14

ORGANIZATION: ANCHOR / DARLING ENTERPRISES, INCORPORATED

-LACONIA, NEW HAMPSHIRE REPORT lNSPECTION 3

NO.: 99901115/90-01 RESULTS:

PAGE 11 of 13 9.

Review of A/DE's Quality Assurance Program The inspectors were particularly interested in the status of the A/DE QA program dur.ng the period January 1988 - July 1989_when Laconia was transiti ning from B-P to A/DI. During the period January 1988 - June ~.988 it appears that the-operations at Laconia, under the d rection of the Hatfield office, relied on

- B-P for QA services. All procurements were.from vendors audited and approved by B-P and the parts receipt inspected by B-P inspectors. All meaufactured parts were also made by B-P under their quality control progrom and the_ finished products were tested and certified by the B-P QA department. Although the QA

-manager from Hatfield visited Laconia occasionally, A/D1 did not have quality control over the products shipped from L conia, B-P did.

The B-P QA program in effect during this period was briefly reviewed by the inspectors and appeared to be adequate.

In June 1988, A/DI issued a QA manual specifically for the Laconia plant and started assuming more of the-QA responsibility, since B-P was significantly reducing the size of its workforce.

The transition to the A/DI system progressed gradually until early 1989 when additional employees were hired and the.

l operations began to change more rapidly.

The Spring of 1989 involved transferring.the entire inventory from Hatfield to-Laconia and, as a final move in the transition, the ASME approved the transfer of the QSC from Hatfield to-Laconia in May.

In July 1989, the Hatfield facility was officially terminated and l

the name of the Laconia facility changed to Anchor / Darling Enterprises, Incorporated, in February 1990, A/DE revised both their 'ASME-Section III and 10 CFR-Part 50, Appendix B, QA manuals significantly to reflect their operations. The ASME conducted another audit of A/DE in June 1990 and renewed their-QSC for another three years.

10.

-10 CFR Part 21 Reports The NRC inspectors reviewed A/DE's processing of an issue that resulted in a 10 CFR Part 21 report from A/DE to the NRC on August 28,1989. The issue involved potential interference problems-associated with a specific structural attachment and snubber body.

The NRC inspectors were interested in how A/DE identified, evaluated, and dispositioned the issue.

The inspectors identified that A/DE's corporate office (located in Hatfield, Pennsylvania) was the first to be made aware of the problem. A sales engineer from A/D1 (Hatfield) received a phone 15

ORGANIZATION: ANCHOR / DARLING ENTERPRISES, INCORPORATED LACONIA, NEW HAMPSHIRE INSPECTION REPORT NO.: 99901115/90-01 RESULTS:

PAGE 12-of 13 call from Pacific Gas and Electric (PG&E) in November 1988.

The sales engineer wrote a memo to PG&E dated November 8,1988, acknowledging the problem and promising to notify all effected customers. However, the sales engineer lef t A/D1 in January i

1989,-and as a result, followup on the issue was not accomplished.

Nothing further happened with this issue until PG&E sent a letter to A/DI (now located in Rosemount, PA) on June 12, 1989, stating that they had corrected the interference problem. PG&E also inquired about whether A/DI was going to process the issue in accordance with the requirements of 10 CFR Part 21.

This letter prompted an interoffice memo from A/D1 (Rosemount) to A/DE on June 21, 1989, stating that they were aware of the problem and had determined that, besides PG&E, only two plants (Vogtle and Arkansas) had affected snubbers. The memo advised that these customers should be notified of the problem and that the affected components should be redesigned.

On July 7,1989, A/DI sent out a letter to the affected plants officially informing them of the problem. The letter stated that snubber installation locations which utilize thy AD-5500 snubber in conjunction with an AD-5505 structure attachment may encounter swing clearance problems-between the stru'.tural attachment and fixed end paddle of the snubber. This inter-ference could introduce additional stresses into tha snubber, which could impair the snubber's ability to perform. The letter further asked that the plants have their engineering staff review those snubber installations utilizing these components _ for the potential interference problem. This action on the part of A/DI fulfilled + heir responsibility under 10 CFR Part 21. A/DE also sent a leti.er to the NRC on August 28, 1989, identifying the problem and stating that their customers had been notified.

The NRC inspectors were concerned with the delay between November 1988 when A/D1 was informed of the problem, and July 1989 when they finally notified their customers. The records relating to this issue and the procedures covering it were not reviewed during the inspection due to the fact that the records were l

stored at the Rosemount, Pennsylvania location. This concern was treated as a " Lesson Learned" during discussions with A/DE personnel on their 10 CFR Part 21 procedures.

The inspectors were satisfied that A/DE personnel appeared to be familiar with the requirements of 10 CFR Part 21 and that they would notify 1

Rosemount personnel of the inspectors' concern over the timeliness issue.

16 l

ORGANIZATION:

ANCHOR / DARLING ENTERPRISES, INCORPORATED l

LACONIA, NEW HAMPSHIP.E l

REPORT INSPECTION NO.: 99901115/90-01 RESULTS:

PAGE 13 of 13 11.

Review of Repair Procedures Associated with the A/DE Snubber Line The inspectors reviewe

'he process that A/DE uses to repair snubbers.

Of particu s'

.terest were the procedures that are used to control the r The review determined that repairs are treated similarly >> new orders when they come in and that they are well documented and thoroughly centrolled.

The process starts when the P0 is received by the A/DE sales staff who then generate a shop order form and a shop order review and release form. These forms allow the shop to test the snubber and then tear it down to identify the problem.

An assently authorization form, generated by engineering in accordance with procedure MF-AA-1, " Preparation and Use of the Assen61y Authorization," then provides a list of material that is required to rebuild the snubber.

The assembly and testing of the snubbers are controlled by procedures specific to the type of snubber being repaired.

A/DE still uses B-P procedures that have not yet been incorporated into the A/DE numbering system.

For example, hydraulic snubbers are assembled in accordance with procedure BP-5-9, " Hydraulic Shock and Sway Arrester Sub-assembly and Pre-calibration Techniques." The procedures reviewed appeared to be adequate, however, an implementation review was not performed during the inspection.

F.

Persons Contacted

1. Peter B. Ellis, General Manager Jeon Keyes-Stewart, Quality Assurance Manager Paul Larose, Mar,ufacturing Manager Walter Paszul, Engineering Manager Attended both entrance and exit meetings

1. Attended exit meeting only 17

+#p ne ~% -

umTro STATES u

8~

i NUCLEAR REGULATORY COMMISSION i,

-[

wAswrow. o. c. mss

\\,...../

Docket No: 99900053/90-01 Mr. George W. Knieser Quality Assurance Manager Anchor / Darling Valve Company 701 First Street P.O.-Box 3428 Williamsport, Pennsylvania 17701

Dear Mr. Knieser:

This letter-and its enclosures refer to the inspection conducted by Mr. R. Pettis and Ms. A. Fitzgerald of this office on November 13-16, 1990, of your f acility at Williamsport, Pennsylvania and the discussions of the findings with members of your staff at the conclusion of the inspection.

The inspection was conducted to review Anchor / Darling Valve Company's (A/DV's) response and implementation of corrective actions to previously identified violations and nonconformances.

A/DV's program for dedication of commercial-grade items (CGI) used in safety-related applications was also reviewed.

During this inspection it was found that the implementation of your quality assurance (QA) program failed to meet certain - NRC requirements.

The most significant problem was the failure of A/DV to adequately review for suita-bility spare / replacement parts used in nuclear safety-related valves furnished by A/DV to the nuclear industry.

Specifically, A/DV relies upon a sampling method to verify suitability of application of CGIs procured for use in safety-related applications.

This method does not assure that the remaining items procured are identical in all aspects to the item dedicated using the sampling method. The utilization of this method appears to have contributed to the problem in which several licensees received actuator rebuild kits for Feedwater and Main Steam Isolation Valves which contained o-rings of incorrect material (Buna-N instead of Viton).

A/DV submitted a 10 CFR Part 21 report to the NRC on January 30, 1990, which stated that the incorrect material could cause operational problems which could adversely affect the safety-rela ted function of the valves.

A/DV also stated that all orders for safety-related o-rings processed af ter February 12, 1990, will receive dedication on a 100%

basis.

During the inspection, A/DV stated that at present there were no plans to apply the 100% method to items other than o-rings which are procured as a CGI for use in safety-related applications.

It was also identified during the inspection that A/DV failed to perform implementation

audits, as required by 10 CFR Part 50, Appencix B,

or alternate measures for verifying that suppliers of safety-related material-holding a Quality Systems Certificate issued by the American Society of

- Mechanical Engineers (ASME) are effectively implementing-the approved QA programs.

18

~. _ _ _ _. _ _ _ _ _ _ _. _. - -

George W. Knieser The -specific findings and references to the pertinent ' requirements are identified in the enclosures to this letter.

Areas examined during the inspection and our findings are discussed in the enclosed report.

The inspection consisted of an examination of procedures and representative records, interviews with personnel, and observations by the inspectors.

in response to the enclosed Notice of Nonconforsance, please provide us within 30 days from the _ date of this letter, a written statement containing:

(1) a description of the steps that have been or will. be taken to correct these items; (2) a description of the steps that have been or will be taken to prevent recurrence; and (3) the dates that your corrective action and preventive meariures were or will be completed.

We will consider extending the response time if you can show good cause for us to do so.

The responses requested by this letter are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 95-511.

In accordance with 10 CFR 2.790 of the Comission's regulations, a copy of this letter and its appendices will be placed in the NRC's Public Document Room.

In addition, a copy of this report will be forwarded to the ASME for their review and information.

Should you have any questions concerning this inspection, we will be pleased to discuss them with you.

Sincerely,

/

l t Leif J.'Nofrholm, Acting Ch Vendor Inspection Branch Division of Reactor Inspection and Safeguards Office of Nuclear Reactor Regulation

Enclosures:

1.

Appendix A -

-Notice of Nonconformance 2.- Appendix B - Inspection Report No -99900053/90-01 cc: Melvin R. Green, Executive Director Codes and Standards-American Society of Mechanical Engineers 345 East 47th Street New York, New York 10017 19

~. -

Anchor / Darling Valve Company Williamsport, Pennsylvania APPENDIX A NOTICE Of NONCONf0RMANCE During an inspection conducted at the Williamsport, Pennsylvania facility of Anchor / Darling Valve Company ( A/DV) on November 13-16, 1990, the implemen-tation of the A/DV quality assurance (QA) program was reviewed. The results of the inspection revealed that certain activities were not conducted in accordance with NRC requirements.

These items are set forth below and have been classified as a nonconformance to the requirements of 10 CFR Part 50, Appendix B, imposed on A/DV by contract, and the A/DV Quality Assurance Manual.

1.

Criterion XVill of Appendix B to 10 CFR Part 50, " Audits," states, in part: "A comprehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the quality assurance program and to determine the effectiveness of the program.... Audit results shall be documented....

Followup action, including reaudit of deficient areas, shall be taken where indicated."

Contrary to the above; the A/DV QA program does not require program implementation audits or alternate measures for verifying that safety-related suppliers holding Quality Systems Certificates (material) are effectively implementing their approved QA programs.

II. Criterion Ill, " Design Control," of 10 CFR Part 50, Appendix B, requires, in part, that measures be established for the selection and review for suitability of application of materials, parts, equipment and processes that are ' essential to the safety-related functions of the structures, systems and-components.

Contrary to the above, A/DV failed to adequately review for suitability commercial-grade items (CGIs) used in safety-related applications.

Specifically, A/DV's dedication is based primarily on a sampling basis which is inadequate to assure that the remaining items are similar to the item selected for dedication and suitable for their intended appli-cation. The fellowing examples were identified during the inspection:

20

Anchor / Darling Valve Company Williamsport, Pennsylvania-a.-

Resilient seats used in several 4-inch, 1,535 pound Tilting Disc Cht;\\ Valves supplied to Carolina Power and Light under Purchase Order (PO) No. 693153AN for the Harris Nuclear Plant.

b.

Barksdale pressure switches used in several 20-inch, 900

sound, Double Disk Gate Valves supplied to Florida Power and Lig1t Company under PO No. C90930-91310 for the St. Lucie Nuclear Plant, in both examples A/DV dedicated only one item and extended the results of such dedication to the remaining items procured without assuring that the item sampled was representative of the procurement lot. This method does not assure that CGIs, procured for use in safety-related applications from commercial suppliers, are suitable for their intended application. Such-suppliers may not control manufacturing lot traceability or document changes in design, material and manufacturing, i

The sampling method employed by A/DV appears to have contributed to the problem in which several licensees received actuator rebuild kits for Feedwater and Main Steam Isolation Valves which contained o-rings of incorrectmaterial-(Buna-NinsteadofViton). This resulted in A/DV-issuing a 10 CFR Part 21 report to the NRC on January L30,1990.

l l

l 1 -

1; Dated in Rockville, Maryland this-day of

,1991 I

l. :

21 I

ORGANIZATION: ANCHOR / DARLING VALVE COMPANY WILLIAMSPORT, PENNSYLVANIA REPORT INSPECTION INSPECTION N0.:99900053/90-01 DATE: November 13-16, 1990 ON-SITE HOURS: 64 CORRESPONDENCE ADDRESS:

Mr. George W. Knieser, QA Manager Anchor / Darling Valve Company 701 First Street P.O. Box 3428 Williamsport, Pennsylvania 17701 ORGANIZATIONAL CONTACT: Mr. George Knieser TELEPHONE NUMBER:

(717) 327-4825 NUCLEAR INDUSTRY ACTIVITY: Manufacturer of valves including spare / replacement parts used in nuclear safety-related applications.

ASSIGNED INSPECTOR:

[

Y. -(-

d

/

R. L. Pettis, Jr., Reactive Inspection Section Date No. 1 (RIS-1), Vendor Inspection Branch (VIB).

OTHER INSPECTOR (S):

A. Fitzgerald, VIB t

APPROVED BY:

11 d d

} _

2-1-$

U. Potapovs, Chie'f, RIS-'L, G

Date INSPECTION BASES AND SCOPE:

A.

BASES:

10 CFR Part 50, Appendix B; 10 CFR Part 21; ASME Boiler and Pressure Vessel Code, Section Ill, Division 1.

B.

SCOPE: Review previous inspection findings,10 CFR Part 21 reports, and Anchor / Darling Valve Company's program for dedication of commercial-grade items used in safety-related applications.

1 PLANT SITE APPLICABILITY: Multiple plant sites.

I 22

ORGANIZATION: ANCHOR / DARLING VALVE COMPANV WILLIAMSPORT, PENNSYLVANIA REPORT INSPECTION NO.: 99900053/90-01 RESULTS:

PAGE 2 of 10 A.

VIOLATIONS:

No violations were identified during the inspection.

B.

HONCONFORMANCES 1.

Contrary to the requirements of Criterion XV111. " Audits," of Appendix B to 10 CFR Part 50, A/DV's QA program dues not require implementation audits or alternate measures for verifying that suppliers of safety-related material holding Quality Systems Certificates (QSC) issued by the American Society of Mechanical Engineers (ASME) are effectively implementing the approved QA programs. (90-01-01) 2.

Contrary to Criterion 111. " Design Control," of Appendix B to 10 CFR Part 50, A/DV f ailed to adequately review for suitability spare / repin ement carts purchased commercial-grode and used in safety-related applications as referenced below; a.

Resilient seats used in a 4-inch, 1535 pound Tilting Disc Check Valve supplied to Carolina Power and Light under Purchase Order (P0) No. 693153AN for the Harris Nuclear Plant.

b.

Barksdale pressure switches for a 20-inch, 900 pound, Double Disk Gate Valve supplied to Florida Power and Light Company under P0 No. C90930-91310 for the St. Lucie Nuclear Plant.

A/DV's dedication of these conmiercial-grade items was based primarily on a sampling method which is inadequate to verify suit-ability of the remaining items.

(90-01-02)

C.

UNRESOLVED ITEMS:

No unresolved items were identified during the inspection.

D.

STATUS OF PREVIOUS INSPECTION FINDINGS:

1.

(Closed) Violation (86-01-01)

Prior to the 1986 inspection, P0s from A/DV to its subsuppliers which referenced ASME Section 111 requirements did not specify 10 CFR Part 21 requirements.

Corrective action was taken by l

I i

23

ORGANIZRTION:

ANCHOR / DARLING VALVE COMPANY WILLIAMSPORT, PENNSYLVANIA REPORT INSPECTION N0.: 99900053/90 RESULTS:

PAGE 3 of 10 A/DV after this violation was identified.

To verify this correc-tive action, the inspectors reviewed selected safety-related P0s from 1987, 1988, 1989, ar.d 1990.

In all cases, A/DV invoked the requirements of 10 CFR Part 21.

2.

(Closed)Nonconformance(86-01-02_1 There was no documentation to support a-Rework Ticket for two defects repaired on a Weld Repair Record dated September 4, 1985 for the globe body on Shop Order No. E-6534.

In addition, a Repair Welding and Hardfacing Record dated October 31, 1985 did not contain a sketch for the disc on Shop Order No. E-6534 A/DV's response to this nonconformance provided an explanation of the difference between " Weld Repairs in Upgrading" and " Weld Repairs'in Manufacturing."_ A/DV responded to the missing sketch issue by stating that "the inspector did not draw a picture but

.1 he did make an adequate written description of the repair."

The NRC-inspectors reviewed Sections 10 and 11 of the A/DV QAM during the inspection and verified that a Rework Ticket was not necessary for the Weld Repair Record dated September 4,1985, because it was a weld repair made during upgrading.

3.

(Closed) Nonconformance (86-01-03)

In the_1986 inspection, the NRC iden'.ified that a member from QA had not signed, initialed, or stamped the MRBA block on Material Rejection Notice (MRN) No. 9419 dated April 3, 1985, relating to a valve bonnet on Shop Order No. E-6534-001.

In response, A/DV-stated this was an isolated incident.

To verify corrective action, the NRC inspector. reviewed 150 MRNs from 1990 and verified that they were properly signed.

4.

(Closed) Nonconformance (86-01-04)

A review of qualification records for several nondestructive examination (NDE) personnel revealed that the qualification records did not contain a statement indicating satisfactory completion of training in accordance with A/DV Standard No.

QAS-9.

In-response to this nonconformance, A/DV changed the form used.for initial certification to include a reference to training to QAS-9.

During the inspection the inspector reviewed the certification records for Level 11 and III NDE inspectors which all referenced

-training _to-QAS-9 as of February 28, 1989.

24

l ORGANIZATION: ANCHOR / DARLING VALVE COMPANY WILLIAMSPORT, PENNSYLVAEiA I

REPORT INSPECTION NO.: 99900053/90-01 RESULTS:

PAGE 4 of 10 5.

(Closed) Nonconformance (86-01-05)

There was no documented evidence that a file of Final Approved Vendor Procedures existed f or ASME Section 111 valves on Shop Order Hos. E-6534, E-6516 and E-3256. Additionally, the file for E-3326 did not contain a copy of Cann & Saul heat treat Procedure No.1023, Revision 4 which was used on the bonnet material.

In response to this nonconformance, A/DV revised procedure MPDS-7 on January 22, 1986, to include a section for standard procedures.

Approved vendor procedures that are not unique to a shop order are defined as standard procedures which are not required to be main-tained with each shop order. The NRC inspector reviewed MPDS-7 and verified that it reflects current practice.

6.

[ Closed) Nonconformance (86-01-06)

During an inspection of the shop (and calibration laboratory, it was noted that two spring gages 0154 and 1395) were not labeled properly to indicate calibration. The balonce scales, surface plate, and dead weight tester also were not correctly labeled to indicate removal from service.

The NRC inspector toured the calibration laborotory and verified that all equipment had calibration labels. Calibration records for all equipment are maintained in the calibration laboratory.

7.

(Closed) Nonconformance (86-01-07)

Acceptable seat rings were found in a nonconforming material hold area with nonconforming material. A/DV's responses to the NRC on June 27, 1986, stated that the material had been on hold.

However, upon identification by URC, the items were removed from hold and placed in an accepted area.

8.

(Closed) Nunconformance (86-01-08)

Stainless steel burr wheels were not marked in yellow. A/DV's response to the NRC was that corrective action was implemented on January 17, 1986.

9.

(Closed) Nonconformance (86-01-09)

An unmarked box of Sandvik welding electrodes was lef t in the weld area after completion of a job; unmarked stellite rods were not in containers in the welding material storage area; bare wire 25

ORGANIZATION: ANCHOR / DARLING VALVE-COMPANY--

WILLIAMSPORT, PENNSYLVANIA REPORT INSPECTION NO : 99900053/90-01 RESULTS:

PAGE 5 of 10 remaining on a wire feeder after sags'4as not covered; and the temperature in an oven conttiaing ISO 9L electrodes was below 225'F on two occasions. A/bV responded that the weld material control problems were correcteo en Jrxary 17, 1986.

10. ~(Closed) Nonconformance (86-01-10)

Vendor corrective actions, as indicated on VHDRs, were not audited for implementation by A/DV QA. The restriction resulting from the January 1985 vendor audit of Effort Foundry was not identified in the Approved Vendor List (AVL). Additionally, R.E.C. was not audited within the 12-month frequency.

The NRC inspector verified that A/DV had corrected these problems by revising their audit checklist (MQCS-11-1) and by adding restrictions to the AVL.

The restriction on Effort Foundry was added to.the AVL on April 8, 1987.

R.E.C. was verified on the October 1990 AVL as a supplier of non-pressure boundary material.

Verification of vendor corrective action is currently documented as part of the audit report.

It should be noted that an MRN is now used to report material deficiencies. Vendor corrective action, as indicated on MRNs, is audited for implementation by A/DV's-QA staff. MQCS-11-1, Revision S, contains a check-off item for implementation of corrective action.

11. iC1osed) Nonconformance (86-01-11)

Of 373-VMDRs issued during 1985, 19 were still open and exceeded the ten working day response-reqt.irement. A/DV responded that ten working days was not adequate to obtain a vendor's response. As a result, A/DV extended the requirement to 30 days.-.The NRC inspector verified that the current procedure for nonconforming.

material and MRB disposition, MQCS-2, Revision AB, paragraph 6.6.1, states that the required response time is now 30 days.

12.

(Closed) Nonconformance (86-01-12)

Training on revisions to the QAM dated November 1,1984, and December 3, 1985 for the Manufacturing Manager, Engineer, Planner, Assembly Department Supervisor, Store Supervisor, and Machine Foreman, did not exist. A/DV responded that the Manufacturing Manager has been re-instructed on the training requirements of the QA manual on April 11, 1986, and January 15, 1986.

26

ORGANIZATION: ANCHOR / DARLING VALVE COMPANY WILLIAMSPORT, PENNSYLVANIA REPORT INSPECTION NO.: 99900053/90-01 RESULTS:

PAGE 6 of 10 The current A/DV practice is that new revisions of the QAM are sent so managers accompanied by a memo that highlights areas that have been revised and also provides a summary of each revision.

The managers are responsible for applicable training.

13.

(Closed)Nonconformance(86-01-13)

Of 17 Abnormal Occurrence Reports (A0R) issued in 1985, only 3 had a documented evaluation performed on Form OPER-1-2. A0Rs are now evaluated by the Technical Director according to the OPER-1 proce-dure which does not specify a completion time.

E.

INSPECTION FINDINGS AND OTHER COMMENTS:

1.

Review of 10 CFR Part 21 10 CFR Part 21 responsibilities are included on P0s from A/DV to suppliers of Category 1 and Category 2 materials. A/DV's system for reporting defects states that once a deviation is identified, it is evaluated in accordance with OPER-1, entered on the appro-priate form and affected customers notified if it is determined that the item is reportable to the NRC.

The inspectors reviewed the following A0Rs which were reported to the NRC in 1990.

a.

(Closed) 10 CFR Part 21 (89-098)

In 1989, an incorrectly sized steia nut was discovered in a motor-operated valve at the Clinton Power Statinn.

Illinnis Power Company reported this matter to the !MC in accordance with 10 CFR Part 21. The 20-inch diameter gate c.lve was intended for use in the High Pressure Core Spray System.

A/DV assembled the valve using a 2-inch stem nut to couple the actuator to the 1 3/4-inch diameter stem.

The valve in question was supplied in 1977 by A/DV's Hayward, California plant. This is believed to be an isolated incident because this type of valve was only supplied to two plants.

Both plants invcived were notified and there were iso similar problems found, b.

(Closed) 10 CFR Part 21(90-018and30-016]

Kansas Gas and Electric discovered that backup o-rings furnished by A/DV in spare parts seal kits contained the 27

ORGANIZATION: ANCHOR / DARLING VALVE COMPANV WILLIAMSPORT, PENNSYLVANIA REPORT INSPECTION NO.: 99900053/90-01 RESULTS:

PAGE 7 of 10 wrong material.

A specific gravity test was developed by A/DV for verification testing of the o-rings. All licensees that had received these kits were notified by A/DV of the problem by letter on Janusry 26, 1990.

2.

Vendor / Supplier Audit Program The NRC inspectors selected for review several safety-related suppliers listed on A/DV's AVL for both Category 1 and 2 material.

Category 1 material is used in pressure-boundary applications, where Category 2 material is used for nonpressure boundary, safety-related applications.

Items which fall into this category (pilot operated, check, hydraulic, pneumatic, include, but are not limited to, screws, various small valves solenoid operated), o-rings, resilient valve seats, hinge pins, valve discs and pressure switches.

Such items normally f all outside of ASME pressure boundary requirements but are considered safety-related with respect to the function they perform within the valve.

The mei. hod for placing and maintaining a vendor on the AVL is described in Chapter 9 of the A/DV QAM. Section 9.4.1.5 speci-fies the audit frequency and criteria for specifying a vendor on the AVL.

Vendors on the AVL are audited by A/DV QA to be maintained on the AVL and are audited to NCA-3800 in accordance with A/DV procedure MQCS-11.

The Vendor Audit Checklist is used to record the information.

The NRC inspector reviewed audit reports for the following Category 1 and 2 suppliers:

Mountain Alloys; Parker Hannifin; Teledyne Republic; and Quaker Alloy.

The results of these audits were reflected on the AVL for the proper category including vendor restrictions.

The AVL is updated every three months to reflect recent audit information.

It should be noted that, if the supplier holds an ASME QSC, A/DV's program does not require audits to verify implementation of the supplier's approved QA program. Section 5.2 of A/DV Standard No. MQCS-11, Revision V, dated November 1990, states that the performance of vendors holding a QSC shall be reviewed at least once for every four purchase orders. The validation process may consist of an audit to verify program implementation or a retest of the material to ccnfirm compliance to the specification.

28

ORGANIZATION:

ANCHOR / DARLING VALVE COMPANY WILLIAMSPORT, PENNSYLVANIA REPORT INSPECTION H0.: 99900053/90-01 RESULTS:

PAGE 8 of 10 Product verification utilizing the one out of four P0s approach is not considered adequate to establish confidence that the vendor is adequately implemer. ling its approved QA program.

This item was p(APSC) in June 1989.reviously identified to A/DV by Arizona Public Service Com A/DV's response in a letter dated October 12, 1989 stated that A/DV would verify every beat of material fron QSC holders that are used on all APSC orders 6nd would include a verification of chemical and physical properties.

However, this 1001 verification process is only used on ATSC orders.

A/DV stated to the NRC inspectors that APSC is the snly customer which imposed the requirement to verify QA program iirplementation of QSC holders. At present, the 100% method cr alternate measures for verifying quality is not assured en A/DV orders with other nuclear customers.

Licensee / suppl 6r responsibilities in this area are discussed in NRC Infornution Notice 86-21, issued March 31, 1986.

Nonconformance 30-01-0} was identified during this part of the inspection.

l 3.

Dedication of Commercial-Grade Items (CGl's) Used in Safety-Related ApplTcations.

The inspectors reviewed A/DV's procedure for dedication of CGl's used in Category 2 safety-related applications (non-pressure boundary).

The dedication process is described in A/DV Standard No. ES-21,

" Technical Evaluation and Dedication," dated October 19, 1989, which is based in part on the guidelines contained in Electric Power Research Institute Report No. NP-5652, " Guidelines for the Utilization of Commercial-Grade items for Nuclear Safety-Related Applications (NCIG-07)." This report has been condi-tionally endorsed by the NRC in Generic Letter 89-02, dated t' arch 21,1989.

The A/DV standard is intended for use on Category 2 items where the customer has ir.iposed the requirements of Appendix B to 10 CFR Part 50 and/or 10 CFR Part 21.

Category 1 items (pressure boundary, safety-related) are purchased from audited vendors who maintain an approved Appendix B QA program.

A/DV initiated ES-21 for all orders quoted after December 1, 1989, and has since processed approximately 400 technical evaluations, 29

ORGANIZATION: ANCHOR / DARLING YALVE COMPANY WILLIAMSPORT, PENNSYLVANIA-REPORT INSPECTION N0.: 99900053/90-01 RESULTS:

PAGE 9 of 10 250 of which comprised o-rings used in safety-related valve actuator rebuild kits for feedwater and Main Steam Isolation Valves.

The NRC inspector selected the following dedication packages for review during the inspection:

a.

P0 No.- 693153AN, dated May 16, 1990, from Carolina Power and Light for safety-related resilient seats associated with a 4-inch,1535 pound Tilting Disc Check Valve for the Harris nuclear plant. The P0 invoked 10 CFR Part 21 and 10 CFR 50, Appendix B, requirements on A/DV and its subsuppliers. A certificate of conformance to the PO was also required. A review of the Technical Evaluation Worksheet For Safety-Related items, Form ES-21-1, dated September 19, 1990, for A/DV Part No. B64313RK (resilient seats) indicated that dimensions and material are the critical characteristics necessary to dedicate the item.

The tests or inspections necessary to verify these characteristics consisted of a 100% inspection to verify dimensions per A/DV drawing B64313 and a specific gravity test to verify the proper material, in addition, a micro-hardness test was specified.

Although this process appeared to be adequate to dedicate commercial-grade seat material, the tests described above to verify proper material are only performed on a sample of items procured, not the entire lot. This-method does not assure equivalency to the tested item since commercial-grade suppliers routinely make changes in design, manufacturing, and materials without the purchaser's knowledge, in addition, A/DV does not audit the commercial-grade suppliers' QA program to verify the validity of statements nade in certificates of conformance.

A/DV representatives stated that they purchased these items directly from Parker-Hannifin (P-H) 0-Ring Division, which is audited and listed as an approved supplier. The last audit of P-l! was performed on July 27, 1990, in which P-H was classified as a supplier of Category 2 material.

The audit was performed at P-H's manufacturing facility.

However, A/DV is only permitted by P-H to purchase such material from an authorized P-H distributor. As such, lot or batch traceability cannot be assured, verified or relied upon. Therefore, 100% of the items purchased must be dedicated.

30

ORGANIZATION: ANCHOR / DARLING VALVE COMPANY WILLIAMSPORT, PENNSYLVANIA REPORT INSPECTION NO.: 99900053/90 01 RESULTS:

PAGE 10 of 10 This sampling aaproach appears to have contributed to the problem in whic1 several licensees received actuator rebuild units for Feedwater and Main Steam 1 solation valves which containedo-ringsofincorrectmaterial(Duna-Ninsteadof Viton). This resulted in A/DY issuing a 10 CFR Part 21 report to the NRC on January 30, 1990, which stated that the incorrect material could cause operational problems which could adversely af fect the saf ety-related function of the valve.

b.

P0 No. 90930-9130 dated June 21, 1990, from Florida Power and Light (FP&L) for two safety-related Barksdale pressure switches used for a 20-inch 900 pound Double Disk Gate Valve for the St. Lucie Nuclear plant. 1he PO invoked 10 CFR Part 21 and required A/DV to provide certification that the switches provided are identical nr functionally interchangeable with the original model so as not to affect the original qualification test report performed by Wyle.

A review of the Technical Evaluation Worksheet For Sufety-Related items, Form ES-21-1, dated August 31, 1990, for A/DV Part No N31190 (Barksdale No. B2T-A-48SS) indicated that vendor part nunber, material and pressure integrity are the critical characteristics necessary to dedicate the item. The inspection necessary to verify these characteristics consisted of a visual inspection to verify part number and a verification of calibration for 100% of the items.

1 i

However, the tests required to verify material (Bourdon Tabe) and pressure integrity (hydrostatic test) are only required to be performed on a scmple basis.

Asstatedinitem(a) above, this method does not assure equivalency to the item selected for testing since commercial-grade suppliers routinely make changes in design, manufacturing and materials without the purchaser's knowledge. A/DV purchased the switches from IMO Industries, incorporated as a CGI and certified to FP&L that the items were identical to the original item supplied and would not affect the original qualification report perforned by Wyle on May 23, 1978.

Nonconformance 90-01-02 was identified during this part of the inspection.

F.

PERSONS CONTACTED G. Knieser Quality Assurance Manager W. Knecht, Technical Director J. Chappell, P.E., Engineering Manager 31

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JAN 3 01991 Docket No. 99901024/89-01 Mr. J. Rider General Electric Apparatus Service Shop 5134 Peach Tree Road Chamblee, Georgia 30341

Dear Mr. Rider:

This letter addresses the inspection of your f acility at Chamblec, Georgia, conducted by Mr. K. R. Naidu of this office and other members of the NRC staff on April 21, 1989, a.id the discussions of their findings with Mr. P. M. Briggs and other members of General Electric Company at the conclusion of the inspection.

Release of this report was delayed due to the NRC's ongoirg review of nonconforming and substandard vendor products.

The purpose of the inspection was to observe the disassembly of three THEF 1360$0 molded case circuit breakers brought to your shop by Prairie Island Nuclear Power Station personnel. The inspection consisted of an examination of representative records and observations by the inspectors during the disassembly of the three THEF 136050 molded case circuit breakers.

In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Room.

Should you have any questions concerning this inspection, we will be pleased to discuss them with you.

I Sincerely, f/ sad

/

-W Edward T. Baker, Acting Chief Vendor Inspection Branch Division of Reactor Inspection l

and Safeguards l

Office of Nuclear Reactor Regulation

Enclosure:

Inspection Report 99901024/89-01 32

1 ORGANIZATION: GENERAL ELECTRIC APPARATUS SERVICL SHOP CHAMBLEE, GEORGIA REPORT INSPECTION INSPECTION NO.: 99901024/89-01 DATE: April 21, 1989 ON-SITE HOURS: 6 CORRESPONDENCE ADDRESS: General Electric Apparatus Service Shop 5134 Peach Tree Road Chamblee, Georgia 30341 ORGANIZATIONAL CONTACT: Mr. J. Rider TELtPHONE NUMBER:

(404) 452-4800 hUCLEAR INDUSTRY ACTIVITY: Maintenance on electrical switchgear.

'l 4

ASSIGNED INSPECTOR:

e LO^ d ( t i//dP)

K. R. Naidu,) Reactive Inspection Section No. 1 Date (RIS No. 1 OTHERINSPECTOR(5):

T. J. O'Connor, inspector, Region !!!

J. H. Neisler, inspector, Region !!!

N. Merriweather, inspector, Region 11 7'A. B. Ruff, inspector, Region !!

N(

vb APPROVED BY:f.,E. T. Baker, Chief, RIS No.1, Vendor Inspection 0 ranch URT J

INSPECTION BASES AND SCOPE:

A.

BASES:

10 CFR Part 21; 10 CFR Part 50, Appendix B.

B.

SCOPE: Witness the disassenbly of three THEF 136050 molded case circuit breaTers purchased by Northern States Power Corporation for use in Prairic Island nuclear power station; and review the results of electrical tests performed on eight THEF 136050 molded case circuit breakers.

PLANT SITE APPLICADILITY:

Prairie Island Units 1 and 2, 50-282 and 306.

33

i ORGANIZATION:

GENERAL ELECTRIC APPARATUS SERVICE SHOP CHAMBLEE, GEORGIA REPORT INSPECTION NO.: 99901024/89-01 RESULTS:

PAGE 2 of 5 A.

VIOLATIONS:

No violations were identified during this inspection.

B.

N0l.CONFORMANCES:

No nonconformances were identified during this inspection.

C.

UNRESOLVED ITEMS:

No unresolved items were identified during this inspection.

D.

INSPECTION FINDlhGS AND OTHER COMMENTS:

1.

Background Information This inspection was conducted to witness the disassembly of selected 480 volt, THEF 136050 molded case circuit breakers (LB) manufactured by the General Electric Company (GE).

These CBs had been procured by Prairie Island nuclear power plant (PI). During an NRC inspec-tion at P1 conducted during October 24 through November 4,1988, NRC inspectors identified that F1 had purchased 16 THEF 136050 CBs from Lakeland Engineering Equipment Company (LEEC) located in Minneapolis.

It was subsequently determined that LEEC obtained the circuit breakers from B. Ferguson Industrial Control Supply, incor-porated (FISC) located in Whittier, California.

The results of the Pl inspection are documented in NRC Inspection Report 50-202/88-201; 50-306/88-201.

FISC, who is not an original manufacturer of the CBs, supplied the CBs marked "used."

The status of the CBs is as follows:

a.

One of the 16 CBs failed a preliminary electrical test during receipt inspection testing conducted by the licensee and the CB was discarded, b.

Eight of the CBs were installed after being dedicated by the licensee and are reported to be in service, c.

The remaining 7 CBs, which were being stored as spares, were delivered to General Electric's Apparatus Service Shop (GEASS) in Chamblee, Georgia, for tests and examination.

34

ORGANIZATION: GENERAL ELECTRIC APPARA105 SERVICE SHOP CHAMBLEE, GEORGIA REPORT INSPECTION h0 : 99901024/89-01 RESULTS:

PAGE 3 of 5 P1 arranged to conduct selected electrical tests at GEASS on the CBs including the disassembly of at least three of them.

Pi includedwiththisbatchofsevenCDstobetested,aneighthCB which had been supplied to P1 and installed as part of the original equipment.

The licensee representative stated that the CB had been in operation since early 1970 and was expressly removed from service for the purpose of these tests.

2.

Details of Tests Performed The tests performed included external inspection of the seven shipping containers in which the CDs arrived at P1 from FISC, external visual inspection of the CBS, selected electrical tests, and disassembly of three CBs and inspection of their internals. The details of these activities are described below:

a.

External inspection of the shipping container This visual inspection included verifying attributes, such as, condition of the shipaing container and the authenticity of the various labels.

Tae inspection determined that several GE shipping labels were counterfeit and appeared to have been made by spraying red paint over a stencil made from an original GE shipping label.

b.

External inspection of the CBs The visual external inspection of the CBs included attributes such at missing or altered labels, damaged surfaces or cracks, and inconsistencies.in the terminal hardware.

The inspection identified that five of the eight CBs were affixed with GE labels xeroxed using original GE labels.

Similarly, the Under-writers Laboratories (UL) labels on seven of the eight CDs were observed to be xerox co)ies of original UL labels. There was no visible indication t1at any of the CDs were opened, s

c.

Electrical tests The electrical tests, which were conducted on the CBs on April 20, 1989, included measurement of contact resistance and-trip time at 200 percent of rated current. The contact resistances on CB identified as nunter seven were determined to be higher than the rest of the CBs.

As a result of this observation, the heat rise at each set of contacts was measured on this CB af ter therral stabilization.

The heat rise on the J

35

-.. =. -.

ORGANIZATION: GENERAL ELECTRIC APPARATUS SERVICE SHOP CHAMBLEE, GEORGIA REPORT INSPECTION NO.: 99901024/B9-01 RESULTS:

PAGE 4 of 5 center phase was measured to be 25-degrees centigrade.

The acceptable heat rise is 50-degrees centigrade according to GE.

To test the insuletion resistance, a Hipot test voltage of 2500 volts ac was applied for one minute between the line and load terminals of each phase of the CB, with the fB open.

1he same yo. cage was applied between the phases and between one phase and the CB case, for each CB, for one minute with the CB closed.

The results on six of the eight CBs tested were normal end met the manufacturer's specifications.

The trip time at 200 percent of rated current on phase A of the CD identified as nun 6er five was 256.B6 seconds instead of 100-250 seconds, it was decided to disassemble the CBs identified as number five and nunber seven and comaare the internals with the CB identified as number three, w1ich is the CB known to have been supplied with the original plant equipment.

The inspec-tors observed that instrurrents with current calibration stickers were used to test the CBs.

d.

Visual inspection of the internal parts The NRC inspectors observed the disassently of the three CBs identified above. A special tool was used to remove the rivets which held the two halves of the CB together.

Visual inspec-tion of the internal parts of the CBS, such as, the moving contacts, stationary contacts, arc chutes, handle, and operating niechanism, indicated that they were genuine parts and that the internal mechanism had not been tampered with.

Information on the inside cover of CB nunber three indicated that the nold data was 1965 and the CB was assembled in 1969. The contacts in this CB exhibited some oxidation indicating that it had interrupted current during its life time. The inside case cover of CB nunter five indicated that it was molded in 1966 and had no manufacturing date code.

The internals of this CB were observed to be very clean, it was concluded that either the CB was preserved well over the years during storage, or the CB was subjected to degreasing operations. The contacts of CB number seven exhibited oxidation indicating that it interrupted current at least once during its life tinie, substantiating that it was a used breaker.

The mold date on the CB cover was 1956 and the manuf acturing date was 1965.

36

ORGANIZATION:

GENERAL ELECTRIC APPARATUS SERVICE SHOP CHAMBLEE, GEORGIA REPORT INSPECTION NO.: 99901024/89-01 RESULTS:

PAGE 5 of 5 F.

PERSONS CONTACTED:

Prairie Island Nuclear Power Plant K. Beadell, Superintendent, Technical Engineering General Electric Company P. M. Briggs, Manager Quality Assurance, Nuclear Plant Services Department, Norcross, Georgia W. J. Heerline, Manager Production & Quality Engineering, Plainville, Connecticut N. Luria Materials Services Engineer, San Jose, California R. Rider Quality Control, GEASS Chamblee, Georgia 6

37

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UNITED STATES l'

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JAN 2 91991 Docket No. 99901112/88-01 Mr. T. Drzich, Manager GE Supply General Electric Company Chicago Region 777 Church Road Elmhurst, Illinois 60126 De3r Mr. Drzich:

This letter addresses the inspection of your f acility at Elmhurst, Illinois, conducted by Mr. K. R. Naidu of this office on July 13, 1988, and the discussions of his findings with you and other c. embers of your staff at the conclusion of the inspection.

Release of this report was delayed due to the NRC's onooin review of nonconforming and substandard vendor products.

The purpor af the inspection was to determine if surplus or refurbished molded case circuit breakers and other electrical equipment mentioned in NRC Information Notice 88-46, including Supplement No. 1, were procured and resold either directly or through distributors to nuclear power plants.

This inspection consisted of an examination of representative records, interviews with personnel, and observations by the inspector.

In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Room.

Should you have any questions concerning this inspection, we will be pleased to discuss them with you.

Sincerely,

V Edward T. Baker, Acting Chief Vendor Inspection Branch Division of Reactor Inspection and Safeguards Office of Nuclear Reactor Regulation

Enclosure:

Inspection Report 99901112/88-01 cc: Mr. A. E. Reisman Division Counsel General Electric Company 1285 Boston Avenue Bridgeport, Connecticut 06601 38

ORGANIZATION: GE SUPPLY ELMHURST, ILLINDIS REPORT INSPECTION INSPECTION NO.:

99901112/88-01 DATE: July 13, 1988 ON-SITE HOURS: 8 CORRESPONDEhCE ADDRESS:

GE Supply General Electric Company 777 Church Road Elmhurst, Illinois 60126 ORGANIZATIONAL CONTACT:

T. Drzich TELEPHONE NUMBER:

(312)530-3547 NUCLEAR INDUSTRY ACTIVITY:

Distributor of electrical equipment, j

4 i

Il

>b Addibhtb thbFttiUK:

• % m t a

1.9 K. R. Neldu, Program Development and Reactive Date Inspection Section OTHER IhSPECTOR(5):

APPROVED BY:

b4 Il-I @

U. Potapovs, Section Chief, W ecial Projects Inspection Date Section INSPECTION BASES AND SCOPE:

A.

BASES:

Follow up inspection to detennine the extent of surplus or refurbished molded case circuit breakers and other electrical equipment supplied to nuclear power plants.

B.

SCOPE:

The inspection consisted of reviewing records to determine if surplus or refurbished molded case circuit breakers (CB) and other electrical equipnent were purchased from sources identified in IN 88-46 and resold to nuclear power plants.

PLANT SITE APPLICABILITY: None identified during this inspection.

39

. ORGANIZATION:. GE SUPPLY FI W!!DRT. IliINfl$

REFORT INSPECTION h0.:

99901112/88-01 RESULTS:

PAGE 2 of 3 A.

STATUS OF PREVIOUS INSPECTION FINDINGS None B.

INSPECTION FINDINGS AND OTHER COMMENTS 1.

Introduction The Nuclear Regulatory Commission (NRC) issued Information Notice (IN) 88-46 and Supplement I to 88-46 to alert owners of nuclear power plants that surplus or refurbished n.olded case circuit breakers and other electrical equipment have been supplied to several nuclear power plants.

The information in the IN was based on the results of inspections conducted at six companies located in the Los Anceles area.

During these inspections, NRC personnel observed sales invoices that indicated that electrical material purchased from these six companies was being supplied either directly or through distributors to nuclear power plants.

Based on information provided in the invoices obtained during the above inspections, this inspection was conducted to determine if such components purchased by GE Supply, Elmhurst, a division of General Electric Company, Fairfield, Connecticut, were resold to nuclear i

power plants.

2.

Review of the Scope of Supply The inspector met with individuals listed in Section C of this report and explained the purpose of the inspection'as stated in the previous paragraph.

The Manager of the Chicago Region explained that the buying and selling of equipment is transacted electronically and that hard copies of the invoices were not available at their locations.

GE Supply is equipped with a cen-tralized billing system located at their headquarters in Bridgeport, Connecticut. A telephone conversation with Mr. A. E. Reisman, Division Counsel for GE Supply located at Bridgeport, Connecticut was arranged during which it was agreed that the inspector would be provided access to tour the facilities at Elmhurst, and to review available documents.

It is also agreed that Mr. Reisman would obtain hard-copies of invoices from the branch offices of all transactions with the companies identified in IN 88-46, and make them available-at Bridgeport for review by the NRC.

1 1

3.

Observation of the Storage Area The inspector observed that-the inventory consisted only of CBs i

40 1

~

ORGANIZATION:

GE SUPPLY r!M40PST. ILLINOIS REPORT INSPECTION N0.:

99901112/88-01 RESULTS:

PAGE 3 of 3 and other electrical equipn.ent manufactured by GE and were in original cartons.

The inspector did not observe any CBs or electrical equipment either supplied by the companies mentioned ir IN 88-46 or by competitors to GE in the warehouse area or in i

the staging area being prepared for shipment.

4 Exit Interview The inspector met with the personnel identified in Section C and thanked them for providing access to the facilities and for the information supplied.

C.

LIST OF PERSONS CONTACTED Name Title T. Drzich Manager, Chicago Region M. L. Stephenson Manager, Distribution Support Operation J. I. Vowles Manager, Customer Support D. E. Barina Sales Engineer V. J. L'a i n Manager, Central Region Customer Service Nuclear Energy Customer Service Department 41

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JAN 2 91931 Docket No. 99901123/88-01 Mr. Robert B. Walker, Manager Branch Operations GE Supply General Electric Company 9319 Telstar Avenue El Monte, California 91713

Dear Mr. L iter:

This letter addresses the inspection of your f acility at El Monte, Calif ornia, cond9cted by Mr. K. R. Haidu of this office on August 10, 1988, and the discussions of his findings with you at the conclusion of the inspection.

Release of this report was delayed due to the NRC's onguirig review of nonconforming and substandard vendor products.

The purpose of the inspection was to determine if surplus or refurbished molded case circuit breakers and other Electrical equipment mentioned in NRC Information Notice 88-46, including Supplement 1, were procured and resold either cirectly or through distributors to nuclear power plants. This inspection consisted of an examination of representative records, interviews with personnel, and observations by the inspector.

in accordance with 10 CFR 2.790 of the Commission't regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Room, Should you have any questions concerning this inspection, we will be pleased to discuss them with you.

Sincerely,

./

W

+

Edward T. Baker, Acting Chief Vendor Inspection Branch Division of Reactor Inspection and Safeguards Office of Nuclear Reactor Regulation

Enclosure:

Inspection Report 99901123/88-01 cc: Mr. A. E. Reisman Division Counsel GE Supply General Electric Company 1

1285 Boston Avenue l

Bridgeport, CT 06601 42

ORGANIZATION:

GE SUPPLY EL MONTE, CALIFORNIA REPORT INSPECTION INSPECTION NO.:

99901123/88-01 DATE:

August 10, 1988 ON-SITE HOURS:

4 CORRESPONDENCE ADDRESS:

General Electric Company GE Supply 9319 Telstar Avenue El Monte, C611fornia 91731 i

ORGANIZATIONAL CONTACT: Mr. Robert B. Walker, Manager TELEPHONE NUMBER:

(818) 307-2948 NUCLEAR INDUSTRY ACTIVITY:

Distributor of electrical equipment.

s ASSICNED INSPECTOR:

i la. [.,

,r ~ 4; K. R. Naidu, Program Development and Reactive Date Inspection Section, VIB:DRIS:NRR OTHERINSPECTOR(5):

APPROVED BY:

ik b

L 4B_- --

10 I 87 U. Potapovs. Section Thief, fpecial Projects Inspection U te Section l

INSPECTION BASES AND SCOPE:

A.

BASE _S:

Follow-up inspection to determine the extent of surplus or refurbished molded case circuit breakers and other electrical equipraent supplied to nuclear power plants.

B.

SCOPE:

The inspection consisted of reviewing records to determine if surpTus or refurbished molded case circuit breakers (CB) and other electri-cal equipment were purchased from sources identified in NRC Information Notice 88-46 and resold to nuclear power plants.

Observed facilities for storage of CBs and spare parts.

PLANT SITE APPLICABILITY:

None identified during this inspection.

43

ORGANIZATION:

GE SUPPLY FtMONTE, CAlIIORNIA REPORT INSPECTION NO.:

99901123/88-01 RESULTS:

pAGE 2 of 3 A.

STATUS Of PREVIOUS INSPECTION FINDINGS None B.

INSPECTION FINDINGS AND OTHER COMMENTS 1.

Introduction The Nuclear Regulatory Commission (NRC) issued Information Notice (lN) 88-46 and Supplement 1 to 88-46 to alert owners of nuclear power plents that surplus or refurbished molded case circuit breakers and other electrical equipment have been supplied to several nuclear power plants.

The information in the IN was based on the results of inspec-tions conducted at six companies located in the Los Angeles area.

During these inspections, NRC personnel observed sales invoices that indicated that electrical material purchased from these six companies was being supplied either directly or through distributors to nuclear power plants.

Based on information provided in the invoices obtained during the above inspection, this inspection was conducted to deter-mine if components purchased by GE Supply, El Monte, a division of General Electric Company, headquartered i: Iairfield, Connecticut, were resold to nuclear power plants.

2.

Review of the Scope af Supply The inspector niet with Mr. R. B. Walker, the Man:ger, Branch Opere-I tions of GE Supply, El Monte and explained the purpose of the inspec-tion as stated in the previous paragraph. Mr. Walker explained that the buying and selling of equipmt.nt is transacted electronically. GE Supply is equipped with a centralized billing system located at their headquarters in Bridgeport, Connecticut.

A telephone conversation witn Mrs. M. Castillo, the Acting Division Council for GE Supply located at Bridgeport, Connecticut was arranged during which it was agrced that the inspector would be provided access to tour the El Monte facilities and to review available documents, it was also agreed that Mrs. Castillo would obtain hard copies of invoices of all sales transactions pertaining to material purchased from suppliers identified in IN 88-46 and resold to nuclear power plants and make them available at Bridgeport to the inspector for review.

3.

Observation of the Storage Area The inspector nbserved that The inventory consisted of only CBs and other electrical equipment manufactured by GE and were in original cartons.

The inspector did not observe any CBs or electrical equipment either supplied by the companies mentioned in IN 88-46 44

i ORGANIZAT IOh:

GE SUPPLY flMONTE, cal.lFORNIA REPORT INSPECTION NO.:

99901123/88-01 RESULTS:

PAGE 3 of 3 Supplement 1 or by competitors to GE in the warehouse area or in the staging area pending shipment.

4.

Review of Records The inspector reviewed the hard copies of purchase orders (PO) to detennine if any components were shipped to Southern California Edison Ccmpany (SCEC).

The inspector observed, from the documents reviewed, that there were no P0s from SCEC intended for use at the San Onofre Nuclear Power Station.

6.

Exit Interview The inspector met with Mr. R. B. Walker and thanked him for providing access to the facilities and for the infonnation supplied.

45

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,, [j NUCLE AR REGULATORY COMMISSION g

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i Jay 3 9 1931 Docket No. 9991124/88-01 Mr. D. Woolf, Manager Branch Ope ations General Electric Supply Company 12640 Knott Street Garden Grove, California 92641

Dear Mr. Woolf:

This letter addresses the inspection of your f acility at Garden Grove, California, conducted by Mr. K. R. Naidu of this office on August 10, 1980, and the discussions of his findings with you and Ms. C. Angelo at the conclusion of the inspection. Release of this report was delayed due to the NRC's ongoing review of nonconforming and substandard vendor products.

1he purpose of the inspection was to determine if surplus or refurbished molded case circuit breakers and other electrical equiptrent mentioned in NRC Information Notice 88-46, including Supplement 1, were procured and resold either directly or through distributors to nuclear power plants.

This inspectim consisted of an examination of representative records, interviews with persatinel, and observatio'is by the inspector.

In accorMee with 10 CFR 2.790 of the Commission's regulations a copy of this letter and the enclosed inspection report will be placed in the NRC's public Document Rootn.

Should you have any questions concerning this inspection, we will be pleased to discuss them with you.

Sincerely,

,,6fAh

].

d Edward T. Baker, Acting Chief Vendor Inspection Branch Division of Reactor Inspection and Safeguards Office of Nuclear Reactor Regulation

Enclosure:

Inspection Report 9991124/88-01 cc: Mr. A. E. Reisman Division Council General Electric Company 1285 Boston Avenue Bridgeport, CT 06601 1

46

l ORGANIZATION:

GENERAL ELECTRIC SUPPLY COMPANY GARDEN GROVE, CAL 1FORN!A REPORT IhSPECT10fi lhSPECTION NO.:

9991124/88-01 DATE:

August 10, 1988 ON SITE HOURS:

4 CORRESPONDENCE ADDRLSS:

General Electric Supply Company 12640 knott Street Garden Grove, California 92041 CEGANIZAT10t;AL CONTACT: Mr. D. Woolf, Manager TELEPH0 tie tiUMBER:

(714)690-9200 NUCLEAR lhDUSTRY ACTIVITY:

Distributor of electrical equipment.

/?

ASIGNED :NSPECTOR:

k -- m / r < l / t_

7 /II/( ('

K. R. Naidu, Program Development and Feactive Date

~~

Inspection Section, VlB:DRIS:liRR OTHER IN5PECTOR(5):

APPROVED BY:

24 94/

9 -2 2,g U. Potapovs. Section Chief, Shecial Projects Inspection Date Section, VIB:DRIS:NRR INSPECT 10ti BASES AND SCOPE:

A.

BASES:

followup inspection to detennine the extent of the use of surplus or refurbished molded case circuit breakers and other electrical equipment supplied to nuclear power plants.

B.

SCOPE: The inspection consisted of reviewing records to determine if surplus or refurbished molded case circuit breaters (CB) and other electrical equipment were purchased from sources identified in IN 88-46 and resold to nuclear power plants.

Observed facilities for storage of CBs and spare parts to see if any such equipment was being prepored for shipment to nuclear poer plants.

PLANT SITE APPLICABILITY:

San Onofre Nuclear Generating Station Units 1, 2, &

3 (50-206;361;362) 47

ORGANIZATION: GENERAL ELECTRIC SUPPLY COMPANY GARDEN GROVE, CAllf0RNIA

'I PEPORT INSPECTION NO,:

99911P4/88-01 RESULTS:

PAGE ? of 3 A.

STATUS OF PREVIOUS INSPECTION FINDINGS None.

B.

INSPEC110N FINDINGS AND OTHER COMMENTS 1.

Introduction The Nuclear Regulatory Conimission (NRC) issued Inf ormation Notice (IN) 88-46 and Supplement 1 to 88-46 to alert owners of nuclear power plants that surplus or refurbished molded case circuit breakers and other electrical equipment have been supplied to several nuclear power plants.

The information in the IN was based on the results of inspections conducted at six companies located in the Los Angeles area.

During these inspections, the NRC personnel observed sales invoices that indicated that electrical material was being supplied either directly or through distributors to nuclear power plants.

Based on information pr?vided in the invoices obtained during the above inspection, this inspection was conducted to det* imine if comporients purchased by General Electric Supply Company (GESco), Garden Grove, from the companics listed in IN 88-4G were resold to nuclear power plants.

2.

Eeview of,_lhe Scope of Supply The inspector met with Mr. D. Woolf, the Manager, Branch Opera-tions, General Liectrical Supply Company (CESCo), Garden Grove, and Ms. C. Angelo and explained the purpose of the inspection, as stated in the previous paragraph.

It was explained that the buying and selling of equipment is transacted electronically and that hard copies of the invoices were not available at their location.

GESCo is equipped with a centralized billing system located at their headquarters in Bridgeport, Connecticut.

A telephone conversation with Mrs. M. Castillo, the Acting Division Council for General Electric (GE) located at Bridgeport, Connecticut was arranged, during which it wos agreed that the inspector would be provided access to tour the facilities at Garden Grove and to review available documents relative to the purchase of CBs and other electrical equipment from suppliers identified in IN 88-46 and resold to naclear power plants.

48

ORGANIZATION:

GENERAL ELECTRIC SUPPLY COMPANY GARDEN GR0VE, CAllf0RNIA REPORT INSPECTION h0.:

9991124/88-01 RESULTS:

PAGE 3 of 3 i

3.

,0bservation of the Storage Area The inspector observed that the inventory consisted only of CBs and other electrical equipment manufactured by GE which were in original cartons.

The inspector did not observe any CBs or elec-trical equipment either supplied by the companies mentioned in IN 88-4G or by competitors to GE in the warehouse area or in the staging area pending shipment to nuclear power plants.

4.

Review of Records The inspector reviewed the invoices relating to the buying of CBs and other electrical material and the reselling of the cqmponents to Southern California Edison, San Clemente for use in the San Onofre Nuclear Power Generating Stations (SONGS). One purchase order (P0) identified as 8K038001, dated March 2, 1988, from SONGS requested GESCO, Garden Grove, to supply TB42225AF14 and a TB42150AF14 type CBs, each equipped with a shunt trip ano three single ple double throw auxiliary switches. GE Supply order number 137-800 646 AA dated Macch 2, 1988, indicates that these CDs were purchased from GE Circuit Protective Device, Plainville, Connecticut and shipped to SONGS, Besed on these records the inspector deterriined that these CBs were not purchased from the suppliers identified in IN 88-E 5.

Exit Interview The inspector met with the Mr. D. Woolf and Ms. C. Angelo and thanked them for providing access to the facilities and for the information supplied.

49

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NUCLE AR REGULATORY COMMISSION

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l'ebruary 7,1991 Docket No.: 99901208/90-01 Mr. Ken Spraetr President & Chief Executive Officer Performance Contracting, Inc.

P. O. Box 2198 Shawnee Mission, Kansas 66201

Dear Mr. Spraetz:

This letter refers to the NRC inspection conducted by Mr.

R.

Moist on July 19 20, 1990, at your f acility in Shawnee Mission, Kansas, and the discussio1 of the findings with Mr. J. Ganote, Jr., Quality Assurance Manager, of your staff at the conclusion of the inspection.

Release of this report was delayed during NRC's ongoing review of nonconforming and substandard vendor products.

The inspection was performed as a follow-up to a 10 CFR Part 21 repurt subtaitted by Performnce Contracting, Inc. to the NRC on May 25, 1990, regarding the unknown or suspect condition of bolting materials supplied to nuclear power plant facilities.

Areas examined during the NRC inspection and our findings are discussed in the enclosed report.

This inspection consisted of an examination of procedures and r.presentative records, interviews with personnel, and observation by the inspectors.

In accordance with 10 CfR 2.790 of the Commission's ragulations, a copy of this letter and the enclosed inspection report will be placed into the NRC Public Document Room.

Sincerely, I

fy Lief J. Norrholm, Acting Chief Vendor Inspection Branch Division of Reactor Inspection and Safeguards Office of Nuclear Reactor Regulation

Enclosure:

Inspection Report 99901208/90-01 i

l 50

_.. - ~

ORGANIZATION:

PERFORMANCE CONTRACTING, INC.

SNAWNEE MISSION, KANSAS REPORT INSPECTION INSPECTION N0.:99901208/90-01 DATE: July 19-20, 1990 ON-SITE H0'55: 8 CORRESPONDENCE ADDRESS:

Performance Contracting, Inc.

Post Office Box 2198 Shawnee Mission, Kansas 66201 ORGANIZATIONAL CONTACT: Joseph Ganote, Jr., Quality Assurance Manager TELEPHONE NUMBER:

(913)888-8600 NUCLEAR INDUSTRY ACTIVITY:

Insulation systems and associated support struc-tures for piping and equipment within containments of nuclear power plants.

/[bhW/td // //%L h-6 ASSIGNED INSPECTOR:

/8/ fd 3

~

t Rf 5dolph'N. Mo'ist,/ Reactive Inspection Section Dat-No. 2 (RIS-2), Vendor Inspection Branch (VIB)

OTHER PERSONNEL:

APPROVED Y:

30180 Chris AC VanDenburgh, Section Chie7, RIS-2, VIB Ste i

l INSPECTION BASES AND SCOPE:

A.

BASES:

10 CFR Part 21 and 10 CFR Part 50, Appendix B.

B.

SCOPE:

(a) Review Performance Contracting, Inc. (PCI), test laboratory reports relating to physical and chemical attributes of fasteners used in NUKON insulation system support structures, (b) determine if fasteners are used in safety-related applications, (c) review purchase documenta-tion from licensees to PCI and from PCI to subvendors, and (d) determine if licensees were supplied suspect fasteners.

PLANT SITE APPLICABILITY:

The following nuclear power facilities use fric-tional support rings on vessels to support NUK0N insulation systems; Callaway (50-483); Calvert Cliffs, Units 1 and 2 (50-317/50-318); Indian Point, Units 2 and 3 (50-247/50-286); McGuire, Units 1 and 2 (50-369/50-370); Millstone.

51

ORGANIZATION:

PERFORMANCE C0fiTRACTING, I!iC.

SHAWfiEE MISSION, KAfiSAS REPORT INSPECT 10!i 14 0. : 99901208/90-01 RESULTS:

PAGE 2 of 5 Unit 2 (50-3:5); Seabrook, Unit 1 (50-443); South Texas, Units 1 and 2 (50-498/50-499; St. Lucie, Unit 2 (50-389); Three Mile Island, Unit 1 (50-289); Turkey Point, Unit 4 (50-251); Vogtle, Units 1 and 2 (50-424/

50-425); and Wolf Creek, Unit 1 (50-482).

A.

VIOLATIONS:

None B.

HONCONFORMAfiCES:

None C.

UtiRESOLVED ITEMS:

None D.

STATUS OF PREVIOUS lilSPECTION riti0lNGS:

tione E.

IllSPECT10fi FINDifiG AND OTHER COiiMENTS:

1.

Entrance and Exit Meeting The fiRC inspection and investigation team informed Mr. Ganote (Quality Assurance / Control Monager) during the entrance meeting held on July 19, 1990, of the scope of the tiRC visit; our concerns relating to the use and condition of unknown or suspect bolting material supplied to nuclear power plant facilities; and the records desired by the inspection team for this inspection. The fiRC inspector summarized the results of the inspection to Mr. Ganote during the exit meeting conducted on July 20, 1990.

===2.

Background===

On May 25, 1990, PCI notified the NRC, via a precautionary 10 CFR Port 21 report, of an activity which could rer"It in an unknown or suspect condition of bolting nuterials provided to several operating nuclear power plant facilities.

The 10 CFR Part 21 report was submitted as a result of a nesspaper article published by the Kansas City Star on May 18, 1990 The newspaper article indicated an apparent suspicion on behalf of the U.S. Customs Service regarding the authenticity 52

ORGANIZATION:

PERf0RMANCE C0f1TRACTING, INC.

SHAWNEE MISSION, KANSAS REPORT INSPECTION NO.: 99901208/90-01 RESULTS:

PAGE 3 of 5 and reliability (of bolting materials imported and distributed by 15500, Inc.

ISSCO)), of Lee's Sumuit, Missouri.

PCI submitted the 10 CFR Part 21 report because PCI procures bolting materials f rom ISSCO for use in support structures for NUKON Insulation Systems (NIS).

3.

Procurement Activities a.

NULON Insulation System and Support Structures NIS consists of high-temperaturt, fibrous glass insulation enclosed in woven, fibross glass fabric to form a resilient, thermal-insulation wrap f ar reactor containment building area pipes, fittings and equipn.ent of any size and configuration.

Typica', equipment includes steam generators, recirculation pumps, reactor vessels, and pressurizers.

Typical piping includes steam generator letdown piping, reactor coolant system (RCS) piping, steam generator ste6m lines, and pressurizer surge lines.

The insulation is procured from Owens Corning fiberglass Corporation.

The support structures used to hold the insulation on steam generators and pressurizers are comprised of NULON support rings.

EAch NUKON suppurt ring is made up of NUK0N ring segments. The NULON ring segments are attached by spring-loaded coupling devices.

The bolting used for attaching the coupling devices are ASTM A-449 half-inch, hex-head carbon steel bolts of various lengths depending on the application.

The piece parts that are used in fabricating the support structures for the NIS are procured from PCI's sub-tier suppliers.

The NRC inspectors focused their review on the bolting materials used in the NUKON ring segments.

All carbon steel bolts are procured from 155C0. The only supplier that 15500 has used to procure the above mentioned bolts is INFASCO, a Canadian manufacturer.

INFASCO identi-fies their bolts used in this application with a hollow triangle marking on the head of the bolt.

53 4mrm u-

ORGANIZATION:

PERFORMANCE CONTRACTING, INC.

SHAWNEE MISSION, KANSAS REPORT INSPECT 10!i 11 0. : 99901208/90-01 RESULTS:

PAGE 4 of 5 The NRC team reviewed Baltimore Gas and Electric Company Purchase Order (P0) No. 28533MX, dated April 14, 1989, issued to PCI sp?tifying NUKON thermal insulation for use on the steam generators at Calvert Cliffs, Unit 2.

The P0 imposed 10 CFR Part 50, Appendix B and 10 CFR Part 21.

PC1's nuclear specification / order review form was reviewed for this P0 to verify that all the requirements of the P0 were incorporated into the review form. The review form was a standard form used by PCI to document their review of P0s received from their customers.

PCI issued P0 No. 90-11079, dated May 4, 1990, to 15500 requesting carbon steel bolts. This PO imposed the requirements of 10 CFR Part 21 and PCI's product speci' cation standard (PSS) No. B-7 titled, "NUKON Carbon Ste..

Bolts," on ISSCO.

PSS No. B-7 addressed the materials of construction, and the ordering, packaging, shipping, and certification requirements. The NRC inspectors reviewed both this P0 and 1SSCO's Certificate of Quality Conformance that was issued to PC1.

The inspectors determined that the certificate issued by 155C0 met all the rega nrements of PC1's P0. The NRC inspectors reviewed INFASCO's Mill Test Report for Lot No. 90-05-82012 (Heat No. A00777, dated June 12, 1990) which showed chemical analyses and mechanical properties for half-inch, hex-head cap screws.

The inspectcrs did not review the basis for PC1's use or acceptance cf the 155C0 certificates and test reports, b.

Testing of Bolting Material in order to verify that the bolting materials met the specifications for both physical and chemical properties, PCI sent the following material from their stock to an independent testing laboratory (Laboratory Testing, 'qc.):

Sample P0/Date Size Description Lg L65-2212 62pcs

!"-13 UNC x 4" HRR-LX-752 6/5/90 long carbon steel bolt

( ASTM A449-89 Type 1) 54

ORGANIZATION:

PERFORMANCE CONTRACTING, INC.

SHAWNEE MISSION, KANSAS REPORT INSPECTIi NO.: 99901208/90-01 RESULTS:

PAGE 5 of 5 Sample M/Date Size Description Lot L65-20823 3pcs 1-13 x 1-1" long MRR-LX-739 6/15/90 carbon steel bolt (ASTM A449-89, Type 1 SAE J429, Grade 5)

With respect to h L65-2212, chemical and physical analyses were performed on two samples.

The results of thc analyses met the requirements of ASTM A449-89. The remaining 60 samples were thr n subjected to Rockwell hardness testing.

e All of these $7 ples were found to be in conformance with ASTM A449-89. With respect to P0 L65-20823, chemical analysis was performed on all three samples, tensile testing was performed on one sample and Rockwell hardness testing was performed on one sample.

The results of the analyses met tt:e requirements of ASTM A449-89 and SAE J429. Grade 5.

PCI also had 16 half-inch carbon steel double-t6b weld nuts required to meet ASTM A576-79 and 20 half-inch carbon steel, hex-head nuts required to meet SAE J995, Grade 5, tested by the same laboratory with no failures.

The nuts were also supplied by 15500.

Based on the independent testing by PCI and the inspectors review of the p:.carement records and test results, it appears tha'.

the bolts supplied to PCI by 1S500 conformed to the purchase specifications.

F.

gRSONNELCONTACTED PC1

1. • J. Ganote, Jr.

Quality Assurance / Control Manager Power and Process Division

1. • G, Pinsky General Manager, Engineered System Division G. Har Manager, Technical Services Power and Process Division J. Sprowls QA, Supervisor Power and Process Division

1. Present during entrance meeting

• Present turing exit meeting 55

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FEB 2 71991 Docket No. 99901217/90-01 Mr. John A. Dockray, President Radnor Alloys, incorporated 353 West Lancaster Avenue Wayne, Pennsylvania 19007

Dear Mr. Dockray:

This letter addresses the inspection of your facility at Harrison, New Jersey,

, conducted by Messrs. R. L. Cilimberg, M. Glasman, and M. R. Snodderly of this office on December 10-14, 1990, and the discussions of their findings with you and other roenbers of your staff at the conclusion of the inspection.

Iht purpose of the inspection was to follow-up a 10 CFR Part 21 report by Entergy Operations, Incorporated concerning a defect in a section of 2 1/2 inch SA-312 (type 316) stainless steel pipe which had been supplied to Arkansas Nuclear One, Unit One ( Af'0-1) by Radnor Alloys, Incorporated (Radnor) as Class 1 pipe in accordance with Section til of the ASME Code.

Areas examined during the NRC inspection and our findings are discussed in the enclosed report.

This inspottion consitted of an examination of procedures and repre-sentative records, visual examination of nonconforming pipe observation of ultrasonic testing (UT) at Labot atory Testing, Incorporated [LTI), interviews with personnel, and observations by the inspectors.

During this inspection it was found that the implementation of your quality assurance (QA) program failed to meet certain NRC requirements.

A significant finding is that Radnor shipped one piece of 21/2 inch ASME SA-312 Section 111 Class 1 stainless steel pipe to ANO-1 with a lap defect that was not detected by Radnor final inspection.

Our inspection determined that Radnor failed to assure that the lighting in the inspection area met ASME Section V require-ments, nonconforming material was returned to Hub, incorporated without initiating a ccrrective action request form, and incon.plete corrective action was performed on nonconforning elliptical heads returned to RAM Forge and Steel.

The specific finding; and references to the pertinent requirements are identified in the enclosures to this letter.

Please provide u s wi t hin

.~t J' days from the date of this letter a written statement containing:

(1) a description of steps that have been or will be taken to correct thc items identified in the enclosures; (2) a description of steps that havt be'sn or will be taken to prevent recurrence; and (3) the dates your corrective actions and preventive measures were or will be completed. We will consider extending the response time if you can show good cause for us to do so.

56

John A. Dockroy The response requested by this letter is not subject to the clearance procedures of the Of fice of Monagement and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.

In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Room.

Sincerely, r

N v4 y yo Leif J.

ior K olm, Acting Chief Vendor Inspection Branch Division of Reactor Inspection and Safeguards Office of Nuclear Reactor Regulation

Enclosures:

1.

Notice of Nonconformance 2.

Inspection Report 99901217/90-01 57

ENCLOSURC 1 NOTICE OF NONCONFORMANCE Radnor Alloys, incorporated Docket No. 99901217/90 01 Harrisor, New Jersey During an inspection conducted on December 10-14, 1990, the implementation of the Quality Assurance (QA) program at Radnor Alloys incorporated (Radnor) located in Harrison, hew Jersey was reviewed with respect to the supply of material to the nuclear industry.

The applicable QA program requirements are Appendix B to 10 CFR Part 50,10 CFR Part 21, Section 111 of the ASME Boiler and Pressure Vessel Code and various Radnor manuals and procedures.

Based on the results of the inspection, it appears that certain a:tivities at the Radnor facility were not conducted in accordance with these commitments.

These items are listcd below.

1.0 Criterion V of Appendix B to 10 CFR Part 50 requires that activities affecting quality be prescribed by documented procedures and be accomplished in accordance with these procedures.

1.1 Section(4)(C)ofRadnorprocedureQA-50.3,"FinalInspection,"

Revision 2, dated January 30, 1990, requires a 100 percent visual inspection of all accessible surfaces for possible defects, damage, and cleanliness.

Contrary to the above, Radnor shipped one piece of 21/2 inch ASME SA-312 (type 316 stainless steel) Section 111 Class 1 pipe to ANO-1 which contained a lap defect which was detectable by visual inspection (90-01-01).

1.2 Paragraph T-923(a), Article 9, of Section V of the ASME code requires 50 footcandles of light intensity for visual examination to detect small anomalies.

Contrary to the above, Radnor performed visual inspection in a dimly lit warehouse without ensuring that the light intensity is at least 50 footcandles(90-01-02).

2.0 Criterion XVI of Appendix B to 10 CFR Part 50 requires that in the case of significant conditions adverse to quality measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.

Section 16.0 " Corrective Action," of the Radnor Quality Systems Program Manual (QAM),, Revision 1, dated October 4,1988 requires that measures be established to determine and correct causes of deficiencies, deviations and nonconformances, including those caused by vendors.

4 58

- ENCLOSURE 1 Contrary to the above, Radnor failed to determine in a corrective action request to Hub, incorporated what caused the feilure to detect a deviation in minimum wall thickness in 6 inch schedule 40 ASME SA-376 (type 316 stainless steel) Section Ill Class 2 seamless pipe manufactured by Sandvik (90-01-03).

3.0 Criterion XVI of Appendix B to 10 CfR Part 50 requires that in the case of significant conditions adverse to quality, measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.

Section 16.0, " Corrective Action," of the Radnor Quality Systems Program Manual (QAM), Revision 1.datedOctober 10, 1988, requires that measures be established to determine and correct causes of deficiencies, deviations and nonconformances, including those caused by vendors.

Contrary to the above, Radnor failed to determine in a corrective action request to Ram Forge and Steel, Incorporated (RAM) what caused the failure to detect a dimensionsl deviation in the root face of elliptical heads machined by Parker-Metal Bellows (90-01-04).

l Dated at Rockville, Maryland this _ day of

, 1991 59

ORGANIZATION:

RADNOR ALLOYS INCORPORATED HARRISON, NEW JERSEY REPORT INSPECTION INSPECTION NO.: 99901217/90-01 DATE: December 10-14, 1990 ON-SITE HOURS: 80 CORRESPONDEhCE ADDRESS:

Mr. John A. Dockray, President Radnor Alloys Incorporated 353 West Lancaster Avenue Wayne, Pennsylvania 19087 ORGANIZATIONAL CONTACT: Ms. Patty Klaus, Manager of Quality Assurance TELEPHONE NUMBER:

(201)485-0110 NUCLEAR INDUSTRY ACTIVITY: Materials supplier for nuclear, military, and commercial application.

r ASSIGNED INSPECTOR:

/effv-Ihr

-T f/9/

.L.Cilimberg,ReactiveInsp'ctionSectionNo.1 Date (RIS-1)

OTHER INSPECTOR (S):

M. R. Snodderly, RIS-1

11. Glgsman Region II APPROVED BY:

\\ [M/U 1 p 2-H- %

A UI3is Potapovs, Chiefy RIS-1, Vendor Inspection Branch Date INSPECTION BASES AND SCOPE:

A.

BASES:

10 CFR Part 50, Appendix B; 10 CFR Part 21; ASME Section 111 B.

SCOPE:

To review Radnor Alloys Incorporated (Radnor) QA program relative to the supply of material tc Arkansas Nuclear One, Unit One (ANO-1) which was reported by Entergy Operations Incorporated (Entergy) to contain a defect as defined in 10 CFR Part 21.

l PLANT SITE APPLICABILITY: All nuclear plants using hot finished SA-312 (t 316 stainless steel) seamless pipe manufactured by Sandvik Steel (Sandvik)ype 60

l ORGANIZATION:

RADNOR ALLOYS INCORPORATED HARRISON, NEW JERSEY REPORT INSPECTION NO.: 99901217/90-01 RESULTS:

PAGE 2 of 8 A.

VIOLATIONS:

None B.

NONCONFORMANCES:

1.

Contrary to Criterion V of Appendix B to 10 CFR Part 50 and Section (4)(c) of Radnor procedure QA-LO.3, " Final Inspectier.,"

Revision 2, dated January 30, 1990, Radnor shipped one piece of 2 1/2 inch ASME SA-312 (type 316 stainless steel) Section 111 Class 1 pipe to AH0-1 which contained a lap defect which was not detected by Radnor inspection personnel (90-01-01).

2.

Contrary to Paragraph T-923(a) of Article 9 of Section V of the ASME code, Radnor performed visual inspection in a dimly lit wareh<>use without ensuring that the light intensity is at least 50 footcandles (90-01-02).

3.

Contrary to Criterion XVI of Appendix B to 10 CFR 50 and Section 16

" Corrective Action", of the Radnor Quality Systems Program Manual (QAM), Revision 1, dated October 4, 1988, Radnor failed to issue a corrective action request to determine what caused the failure by Hub Incorpurated (Hub) tc detect a deviation in minimum wall thickness in ASME SA-376 ASME Section 111 Class 2 pipe manuf actured by Sandvik (90-01-03).

4.

Contrary to Criterion XVI of Appendix B to 10 CFR 50 and Section 16 of the Radnor QAM, Revision 1, Radnor f ailed to determine in a corrective action request to RAM Forge and Steel (RAM) what caused the failure to detect a dimensional deviation in the root face of elliptical heads machined by Parker-Metal Bellows (90-01-04).

C.

UNRESOLVED ITEM:

The NRC received a combined 10 CFR Part 21 and Licensee Event Report (LER) No. 50-313/90-012-00 dated October 29, 1990 from Entergy on behalf of ANO-1 (licensee) which identified a defect in stainless steel pipe supplied to ANO-1 by Radnor as discussed in Section E below. The licensee re ultrasonic testing (UT) ported that defects detected by their rendered the piping unsuitable for use at ANO-1.

The root cause of the failure to detect the lap defect during UT by Laboratory Testing Incorporated (LTI) was not determined during this inspection. This item will remain open until NRC receives the written reports required by Section 21.21(b)(3) of 10 CFR Part 21 (90-01-05).

61

ORGANIZATION:-

RADNOR ALLOYS INCORPORATED HARRISON, NEW JERSEY REPORT INSPECTION NO.: 99901217/90-01 RESULTS:

PAGE 3 of 8 D.

STATUS OF PREVIOUS INSPECTION FINDINGS:

None E.

INSPECTION FINDINGS AND OTHER COMMENTS:

1.

Entrance and Exit Meetings The NRC staff informed Radnor management representatives of the scope of the inspection during the e': trance meeting on December 10, 1990, and summarized the inspection findings during the exit meeting on December 14, 1990.

===2.

Background===

The NRC received LER No. 50-313/90-012-00 which identified a defect in stainless steel pipe supplied to ANO-1 by Radnor. The licensee identified the heat numbers of the Radnor/ Custom Alloys (Custom)/Sandvik suspect piping as 462942, 478246, and 40324 and stated that the piping did not conform to ASME Section 111 Class I requirements. A welder at ANO-1 visually identified a lap type defect while preparing to make a prefabrication weld on a section of this 21/2 inch ASME SA-312 type 316 stainless steel material to be used. in a high pressure injection system modification. UT of the piping at ANO-1 reported three defects ranging from 1/4 to 1/3 of wall thickness. The licensee determined that the defects rendered the piping unsuitable for use at ANO-1, Radnor purchased the material from Custom in Highbridge, New Jersey as SA-312 without imposing any nuclear requirements on P0 RA 43236-BR dated July 16, 1990.

Custom purchased the material from Sandvik in Scranton, Pennsylvania.

Radnor upgraded the material from Class 2 to Class 1 by testing each piece of material at LTI.

The LTI quality system program has been audited and approved by Radnor and LTI is on Radnor's Approved Vendor List (AVL). The Sandvik/ANO-1 material has been

-rep) laced by Radnur with material from Combustion Engineering (CE.

Radnor has requested that Entergy return the Sandvik material, but the material is still located at ANO-1.

Entergy, Radnor, and LTI are continuing their evaluation of the Sandvik material to determine _ the adequacy of the UT performed by_ LTI and whether-the material exhibits a " workmanlike finish."

62

ORGANIZATION:

RADNOR ALLOYS INCORPORATED HARRISON, NEW JERSEY REPORT INSPECTION NO.: 99901217/90-01 RESULTS:

PAGE 4 of 8 3.

Document Review The NRC inspectors reviewed the data packages covering the Sandvik/ANO-1 material and determined that the certified material

' test reports meet the chemical and mechanical property require-ments of ASME SA-312 316 stainless steel.

Independent testing performed by Hurst laborotories for Entergy agrees with this determination.

The inspectors did not evaluate the adequacy of UT at LTI or the records that documented that testing while corrective action is ongoing by licensee /Radnor/LTI.

The NRC inspectors reviewed several nonconformance-disposition reports (NDR) to determine if adequate corrective actions had been developed and implemented.

Radnor issued NDR 90-12 on September 19, 1990, which documents Ge discovery of a minimum wall nonconformance by a Radnor QA representative during) receipt inspectionoftwolengthsofSA-376(316 stainless steel pipe.

The pipe exhibited heavy grinding marks and was ordered on August 21, 1990, per ASME SA-376 Section !!! Class 2 latest edition and addenda from Hub Incorporated in Exton, Pennsylvania.

Radnor also imposed 10 CFR Part 50, Appendix B and 10 CFR Part 21 on the supplier.

Radnor returned the material to Sandvik Steel (material manufacturer) in Scranton, Pennsylvania on Sep(CAR) tember 27, 1990.

Radnor did not send a Corrective Action Request to Hub to determine the cause and correct the condition as required by Section 16.0.1 of the Radnor QAM, Revision 1.

(See nonconformance 90-01-03)

Radnor issued NDR 90-15 on October 11, 1990, which described 32 elliptical heads that were sold to and rejected by Parker-Metal Bellows (Parker) in Moorpark, California under P0 37242. One item on the PO was 32 eighteen inch seamless stainless steel elliptical heads.per ASME SA-240 (304L stainless steel) Section 111 Class 3 1986 edition no addenda with 10 CFR Part 50, Appendix B and 10 CFR Part 21 applicability.

Radnor passed these requirements on to Ram who supplied the heads to Parker directly. The P0 from Parker to Radnor and from Radnor to RAM required the heads to have a root face dimension of.060 plus.001 minus.030 inches.

Parker issued Rejection Report No. 30025 because the elliptical heads.were received with a root face dimension that varied from

. 010 to 0.235 inches.

In response to the Radnor CAR dated October 11, 1990, RAM stated that the elliptical heads were beveled by Prescor and RAM will solve the problem in the future 63

~. -

ORGANIZAT ION:

RADNOR ALLOYS INCORPORATED HARRISON, NEW JERSEY REPORT INSPECTION NO : 99901217/90-01 RESULTS:

PAGE 5 of 8 by machining the heads at the RAM f acility.

Radnor approved this corrective action on October 18, 1990. Radnor's corrective action did not address why RAM inspection personnel failed to detect the dimensional deviation or what steps RAM would take to prevent shipping material with dimensional deviations in the f u tu re.

The inspectors observed that Section 15.3.C of the RAM QAM requires that packing lists and delivery receipts from suppliers be used to carefully check the dimensions of materials received.

(See nonconformance 90-01-04) 4.

Laboratory Testing Incorporoted LTI performs upgrade testing on material which Radnor purchases as cocmercial grade and sells in accordance with the results of the testing.

In July 1990, LTI tested 880 lineer feet of the Sandvik/ANO-1 material to meet the requirements of ASME SA-312 Section 111 Class 1, NCA 3867.4(e) for mechanical and chemical properties and ASME NB2500 for volumetric UT. After testing, LTI rejected 200 feet for defects which were primarily on the OD of the material and both the accepted and rejected pipe was returned to Radnor who performed final inspection and shipped the acceptable pipe to ANO-1.

An NRC inspector observed activities at LTI relative to their capability for upgrade testing with emphasis on immersion UT of pipe. The inspector toured the facilities, reviewed UT procedures, witnessed onguing immersion UT, reviewed records, and reviewed examiner audits of all UT personnel. Discussions were held with the owner of LTI, the nondestructive testing supervisor and the technician who tested much of the Sandvik/ANO-1 material.

A review of LTI's QAM and procedure UT-Ill-1 for UT of tubular products with diameters less than 6 3/4 inches in accordance with ASME SA-655 did not indicate that surface quality or the condition of the material must be evaluated to ensure that a meaningful UT examination can be performed. Much of the Sandvik/ANO-1 material was not suitable for UT because it was in the solution annealed hot finished condition. This material was in less than average condition in that the surface exhibited oronge peel and excessive grinding (probably performed by Sandvik to remove surf ace defects). The poor surf ace quality of this material produced a noisy return signal during UT as indicated on chert recordings retained at LTI and many of the defects on the 1

64

ORGANIZATION:

RADNOR ALLOYS INCORPORATED HARRISON, NEW JERSEY REPORT INSPECTION NO.: 99901217/90-01 RESULTS:

PAGE 6 of 8 surface of the pipe were difficult to detect due to their orientation.

One defect was a chevron shaped lamination on the OD which was not detected by LTI in July 1990, but was observed and reported as a lap defect by the licensee prior to use of the material at ANO-1.

The licensee and LTI recently reinspected the section of pipe which contained this defect using the same UT method used by LTI in July 1990, and again failed to detect the defect. The defect was detected finally by using a small contact transducer which was skewed normal to the plane of the rejectable portion of the defect, or about 45 degrees. A longitudinally oriented defect was detected in a length of the Sandvik material during a retest at LTI.

LTI performed UT on cold finished pipe manufactured by CE to the same specification as the Sandvik hot finished material except the CE material was dual certified to SA-376 as well as SA-312.

None of the CE material was rejected by LTl.

The inspector reviewed the UT chart recordings of the CE material and found no excessive noise or rejectable indications in the records.

The owner of LTI told the inspector that material like the Sandvik/ANO-1 pipe with such puor surf ace quality had never been upgraded by LTl as ASME Section 111 material or ultrasonically tested as part of an upgrade.

The owner plans to develop procedures for receipt inspection of material to be upgraded to ASME Section 111 requirements.

Established standards for surface quality and inspection of material to these standards prior to UT would have prevented UT of unsuitable material.

This lack of procedural guidance was considered a weakness in the LTI quality system.

An inspector addressed areas of concern identified by the licensee relative to UT of the Sandvik/ANO-1 pipe which involved calibration reference levels and scanning speed.

Calibration levels were not identical from start to finish of a test run.

The inspector reviewed UT chart recordings of the pipe that was re-examined in the presence of licensee representatives.

The axial notch reference levels were 57 percent and 70 percent at the start of the run and 34 percent and 54 percent at the end of the run. LTI procedure UT-Ill-1 indicates that calibration levels should be identical before and after test runs or the material must be retested. The LTI procedure does not take into account that minute shifts of material or search units can result 65

ORGANIZATION:

RADNOR ALLOVS INCORPORATED HARRISON, NEW JERSEY REPORT INSPECTION NO.: 99901217/90-01 RESULTS:

PAGE 7 of 8 in reference level shifts during testing.

LTI has agreed to revise the procedure to bound an acceptable amount of variability in calibration reference levels.

LTI advised the inspector and the licensee that the material did not contain defects that would have been in excess of 20 percent of reference level. The LTI UT Level 111 specialist reviewed the chart recordings to ensure that potential defects did not escape detection without evaluation and none were reported to the inspector.

The licensee questioned whether the scanning speed when related to the pulse repetition rate and equipment response was such that a defect would go undetected and whether the scanning speed was in excess of what was certified.

The inspector reviewed the charts but did not drow any conclusions with respect to code and procedural requirements or calibration relative to scanning speed as required by ASME Section V, Article 5, paragraph T-514.2 and SE-213, paragraph 9.2.

The inspector noted that the shape of the calibration notch for the calibration standard that was used for the UT of the subject material was not listed on the certification document. Paragraph 17.3 of ASME SA-655 indicates that square, U, or V shaped notches be used in calibration standards for UT and allowable dimensions for each of the notch configurations are specified.

LTI agreed that calibration standard vendors would be asked to provide notch shope on future orders since reflection amplitudes from different notch shapes may vary widely depending on the angle, frequency, and vibrational mode of the interrogating sound beam.

5.

Tour of Radnor Warehouse The NRC inspectors toured the warehouse and inspection facilities at Radnor where material intended for nuclear service is received, stored, segregated, and prepared for shipment. The inspectors viewed a portion of the Sandvik/ANO-1 material (about 200 linear feet) that had been rejected by LTI during the UT that was performed to upgrade the material to ASNE Section III Class 1.

This material had been manufactured by Sandvik as ASME SA-312 (type 316 stainless steel) Section Ill Class 2 from heats 462942, 40324 and 478246 which were formed into 2 1/2 inch diameter pipe by the hot extrusion process (hot finished) and sold to Custom in Califon, New Jersey. Sandvik certified that test results and operations performed are in compliance with the requirements of 66

.-... - - ~ -

ORGANIZATION:

RADNOR ALLOYS INCORPORATED-HARRISON, NEW JERSEY REPORT INSPECTION NO.: 99901217/90-01 RESULTS:

PAGE 8 of 8-V 10 CFR Part 21 using a quality program covered by QSC-239, which expires on June 11, 1991.

Radnor' purchased the material from Custom and supplied it to ANO-1 under Entergy P0s 891015 and 890186 after upgrade testing by LTI.

Included in the Entergy purchase from Radnor was pipe manufactured by CE, but none of this material was rejected by LTI or the licensee.

The inspectors observed that the rejccted Sandvik pipe was in the hot finished condition which is allowed by the SA-312 specification. SA-312 also allows the material to be cold finished. The material from heat 40324/ lot 60025 and heat 462942 did not exhibit a " workmanlike finish" as required by paragraph 12 of ASME SA-312.

Both lots of pipe contained chevron-shaped laminations over the outside surface which is commonly known as orange peel. The pipe from heat 462942/ lot 600304 was covered with heavy grinding marks which probably originated at the mill

~

to remove surface defects. The licensee, Radnor, and the NRC inspectors concluded that this rejected Sandvik material did not exhibit a workmanlike finish or appearance.

Radnor had not detected this condition during receipt inspection nor did they detect the lap defect which was shipped _to ANO-1 and discovered by the welder who was fabricating subassemblies for the safety injection system (See nonconformance 90-01-01).

The inspectors observed that the lighting in the inspection area was not of adequate intensity to perform visual' inspection as required by material specifications such as ASME SA-312 and SA-376. ParagraphT-923(a)ofArticle9ofASMESectionV requires that visual inspection be performed in_an area with

-light intensity of _50 footcandles for the detection or study of small anomalies such as those found on the surface of the Sandvik material. Radnor does not document or_ measure the light intensity in the inspection area which appeared to be less than 50 footcandles-(See nonconformance 90-01-02).

.F..

PERSONS CONTACTED:

• J. Dockray, President T.-Hunt, Shop Foreman

1. • K. Kijesky, Quality Assurance Representative

1. • P. Klaus,' Quality Assurance Manager

1. • D. Salvador, Operations Manager

1. Attended entrance meeting

• Attended exit meeting 67

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JAN 2 91991 Docket No. 99901143/88-01 Mr. David Rosenfield, President ROMAC Supply Company 7400 Bandini Boulevard Comerce, California 90040

Dear Mr. Roesenfield:

This letter addresses the inspection of your facility at Commerce, California, conducted by Mr. Kamal R. Naidu of this office on Decenter 8,1988, and the discussion of his findings with you at the conclusion of the inspection.

Release of this report was delayed due.to the NRC's ongoing review of nonconforming and substandard vendor products.

This inspection was conducted to review activities relative to your supply of electrical equipment to the nuclear industry and whether this equipment was properly represented. This inspection consisted of an examination of procedures and representative records, interviews with personnel, and observations by the inspector.

In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Room.

Should you have any questions concerning this inspection, we will be pleased to discuss them with you.

Sincerely, l

Edward T. Baker, Acting Chief -

Vendor Inspection Branch Division of Reactor Inspection and Safeguards Office of Nuclear Reactor Regulation

Enclosure:

Inspection Report 99901143/88-01 68

ORGANIZATION:

ROMAC SUPPLY COMPANY COMMERCE, CALIFORNIA REPORT lilSPECTION -

INSPECT 1011 t

11 0. :

99901143/88-01 DATE: December 8, 1988 ON-SITE HOURS: 8 CORRESP0llDENCE ADDRESS:

ROMAC Supply Company 7400 Bandini Boulevard Comerce, California 90040 ORGANIZAT10flAL CONTACT:

David Rosenfield TELEPHONE NUMBER:

(213) 721-5810 NUCLEAR INDUSTRY ACTIVITY: Distributor of electrical equipment.

)

ASSIGNED !!iSPECTOR:

i/1

(/ r r (1 L 2//7/[

K. R. Naldtr, Reactive Inspection Section f40. 1 Date (RIS-1)

OTHERINSPECTOR(S):

APPROVED BY:

/

M hs 2

l U. Potapovs, Sectio # Chief,~ Reactiv Inspection Section Date (RIS-2)

INSPECTION BASES AND SCOPE:

A.

BASES:

Follow-up inspection to determine the extent of the use of surplus or refurbished molded case circuit breakers and other electrical equipment supplied to nuclear power plants.

B.

SCOPE:

The inspection consisted of reviewing records to determine if surplus or refurbished molded case circuit breakers (CB) and other elec-trical equipment were sold to nuclear power plants.

Interviewed individ-ual sales persons, observed storage facilities for CBs, electrical trans-formers, and spare parts, refurbishing workshop and shipping area.

PLANT SITE APPLICABILITY:

St.Lucie(50-335/389); Nine Mile Point 2 (50-410).

69

ORGAfilZATION:

ROMAC SUPPLV COMPANY C0lViERCE, CALIFORNIA REPORT INSPECTION N0.:

99901143/08-01 RESULTS:

PAGE 2 of 4 A.

STATUS OF PREVIOUS INSPECTION FINDINGS:

None B.

INSPECTION FINDINGS AND OTHER COMMENTS:

1.

Introduction The Nuclear Regulatory Comission (NRC) issued Information Notice (lN) 88-46 and Supplement 1 to IN 88-46 to z.lert owners of nuclear power plants that surplus or refurbished molded case circuit breakers (CB) and other electrical equipment have been supplied to several nuclear pou r plants. The information in the IN was based on the results of inspections conducted at six companies located in the Los Angeles area. During these inspections, NRC personnel observed sale invoices that indicated that electrical material was being supplied either directly or through distributors to nuclear power plants. This inspection was conducted to determine if ROMAC Supply Company (RSC) sold CBs and other electrical equipment to nuclear power plants.

2.

Review of the Scope of Supply The inspector, accompanied by investigators from the NRC Office of Investigations, met with Mr. Rosenfield, President of RSC on December 8, 1988. Mr. Rosenfield stated that he had been President of RSC since early 1985 and provided the following information regarding the activities at RSC:

(a) Molded case circuit breakers (CBs) constituted approximately 10 percent of his total business. Other products and services sold included transformers, repairing transformers, and motor-control centers.

(b) He specifically did not ask for and therefore, did not get Certificates of Conformances for the CBs purchased by RSC for the purpose of reselling them.

(c) Some of the vendors who furnished CBs to him included the following:

1)

Westinghouse Electric Supply Company, Carson, California 2)

General Electric Supply Corapany, El Monte, California 70

.DRGANIZATION:

ROMAC SUPPLY COMPANV COMMERCE, CALIFORillA I

REPORT INSPECTION NO.: 99901143/88-01 RESULTS:

PAGE 3 of 4 3)

Sills Electric Wholesale Company, Sante Fe Springs, New Mexico 4)

Kato General Company, Mankato, Minnesotta 5)

Allen Bradley, Milwaukee, Wisconsin 6)

ADN Associates, London, Great Britain.

(d) The CBs in the warehouse cannot be traced to the vendor who supplied them.

(e) When CBs are opened for any reascn at RSC, they try to tain-tain the integrity of the original labels affixed on the CB denoting the identification of the manufacturer and the Under-writer Laboratory label.

(f) After the CB is reassembled, a clean silicone substance is put on the screws to detect if the CB was tampered with by a customer after it was supplied by RSC.

(g) RSC does not repaint the date codes on the CBs if for some reason they are wiped off during the cleaning process.

(h) All CBs sold are tested for continuity before they are shipped.

RSC has equipment to conduct limited tests on CBs.

2.

Observation of the Storage Area The NRC staff, accompanied by Mr. Rosenfield, toured the warehouse area where CBs are cleaned and tested. The staff also observed factured by Westinghouse (W)ge metal clad circuit breakers manu-low voltage and medium volta and General Electric Company (GE).

Mr. Rosenfield stated that the metal clad CBs were generally pur-chased by the W and GE Service Centers.

RSC personnel were observed cleaning molded case CBs. The test instruments were observed to have current calibration stickers.

3.

Interviews with RSC Sales persons a.

The NRC staff interviewed selected salcs personnel who handled the sales of CBs to NSSS Inc., Jackson, Mississippi that were ultimately delivered to the Nine Mile Point 2 Iluclear Power Plant to obtain additional information on the specification requirements.

71

l REPOR1 INSPECTION NO.-

99901143/88-01 PESULTS:

PAGE 4 of 4 b.

The staff also interviewed the sales person who initiated RSC invoice 42279, dated March 28, 1988, which pertained to the supply of contactor kits, two each for size 3 and 4 starters manuf actured by W to St. Lucie Nuclear Power Plant (SLNPP) located in Florida.

The sales person stated that SLNPP rejected one set of contactor kits each for size 3 and 4 starters because SLNPP observed discoloration of hardware inside the plastic bag. The sales person showed the inspectors a plastic bag containing the kit that was taken from the warehouse.

The color of the hardware was dull even though the plastic bag containing the contactor kit was sealed.

He stated that he shipped additional contactor kits to the same destination.

4.

Review of Documents The inspector reviewed copies of the sales orders during the period 1986-1988 to ascertain if any CBs were sold directly to nuclear power plants.

The inspector did not observe any sales orders to indicate direct shipment to nuclear power plants.

C.

EXIT INTERVIEW:

At the conclusion of the inspection, the NRC staff thanked Mr. Rosenfield for the cooperation extended.

72

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MAR 211991 Docket No. 99901215/91-01 Mr. C. E. Werner, President Southern Mechanical Seals, Incorporated 2324 S.W. 60th Terrace P.O. Box 3778 Hiramar, Florida 33023

Dear Mr. Werner:

This letter addresses the inspection of your facility at tiiramar, Florida, conducted by R. P. McIntyre and S. L. Magruder of this office from January 30-31, 1991, and the discussions of the findings with you at the conclusion of the inspection.

The purpose of the inspcction was to identify the extent to which your cumpany supplies equipment and replacement parts to the nuclear industry and your capability to do so in an acceptable manner. This inspection consisted of an examination of available records, interviews with personnel, and observations by the inspectors.

While the licensees doing business with your company did not specifically invoke through their purchase documents any NRC requirements and consequently none were viol 6ted, we are concerned about the unathorized material substitutions which you made to Florida Power and Light Co. (FP&L).

Specifically, the substitution of valve packing material other than John Crane onto John Crane spools and into John Crane boxes is an unacceptable activity. The NRC will not countenance this type of substitution for any material supplied to licensed facilities.

In accordance with 10 CFR 2.790 of the Connission's regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Room.

Should you have any questions concerning this inspection, we will be pleased to discuss them with you.

Sincerely,

}

U dis Potapovs, c

hi f Vendor Inspection Branch Division of Reactor Inspection and Safeguards Office of Nuclear Reactor Regulation

Enclosure:

Inspection Report 99901215/91-01 l

73

ORGANIZATION:

SOUTHERN HECHANICAL SEALS, INCORPORATED MIRAMAR, FLORIDA REPORT INSPECTION INSPECTION NO.: 99901215/91-01 DATE: January 30-31,1991 ON-SITE HOURS: 8 CORRESPONDENCE ADDRESS:

Southern Mechanical Seals, Incorporated 2324 S.W. 60th Terrace P.O. Box 3778 Miramar, Florida 33023 ORGANIZATIONAL CONTACT:

Mr. Ed Werner TELEPHONE NUMBER:

(305) 966-6616 NUCLEAR INDUSTRY ACTIVITY:

Distributor of commercial-grade valve packing, pump mechanical seals, gaskets, gasket material, high temperature cloth, and industrial compounds. Currently has no nuclear industry activity.

ASSIGNED INSPECTOR:

i A>nA A

Al N

4(

R. P. Mcliityre, Reactive Ifispectiorf Se'ction Date'

~

Ho. 1 (RIS-1), Vendor Inspection Branch (VIB)

OTHER INSPECTOR:

S. L. Ma

, Special Projects Section, VIB APPROVED BY:

6' 3' 8-9 )

Uldis Potapovs, Section Chief, RIS-1, V!B Date INSPECTION SCOPE:

Unnanounced inspection to review records, procedures and determine scope of supply to nuclear facilities.

PLANT SITE APPLICABILITY:

Turkey Point 3 & 4, St. Lucie 1 & 2, Crystal River.

l 74

l ORGANIZATION:

SOUTHERN MECHANICAL SEALS, INCORPORATED MIRAMAR, FLORIDA KLFUKl IN5PECTION N0.: 99901215/91-01 RESULTS:

PAGE 2 of 3 A.

INSPECTION FINDINGS AND OTHER COMMENTS:

1. Background

Southern tiechanical Seals, incorporated (SMSI) is a small, f amily owned and operated (3-5 people) distributor of valve packing, pump mechanical seals, gaskets, gasket material, high temperature cloth, and industrial compounds.

They have been in business, selling maialy in the Scuth Florida area, since 1971.

The current owner, Mr. Ed Werner, has been with the company since 1971 and became president in 1983.

SMSI sells mainly to local municipal water and sewage plants, sugar mills, and exporters.

Until recently, they also sold to the local power company (Florida Power & Light), both to their fossil fuel and nuclear plants.

The primary focus of this inspection was to identify the extent to which SMSI supplies equipment and replacement parts to the nuclear industry.

2. Review of SitSI's Sales to Nuclear Licensees During discussions with Mr. Werner, the inspectors were informed that, with the exception of one sale to Florida Power Corporation (FPC), the only utility that SMSI has ever sold to is Florida Power & Light (FP&L). SMSI did a significant amount of business with FP&L from 1971 until August 1990. At its peak, sales to FP&L constituted approximately 30 percent of SilS!'s business.

The majority of their sales were to FP&L's fossil plants, however, some sales were to nuclear plants.

SMSI sold items from almost their entire product line to the nuclear plants including; gaskets and gasket nuterial, valve packing, spiral wound gaskets, mechanical pump seals, industrial anti-seize compounds, small valves, and high temperature cloth. All of the materials were ardered as commercial-grade, however, FP&L specified that for the FEL-PR0 anti-seize compound, and the SILTEMP high temperature cloth, additional certifications were required.

FP&L classified these orders as nuclear commercial-grade. Mr. Werner stated that he was not familiar with any nuclear requirements or specifications and that none had ever been imposed on SMSI.

SMSI does not have, and has never had, any form of a quality assurance program.

fir. Werner stated that FP&L performed annual audits of SMSI and required them to maintain a rudimentary quality assurance manual containing an organization chart and a simple receipt inspection procedure. The inspectors were unable to review any of the documentation and records l

75

ORGANIZATION:

SOUTHERN MECHANICAL SEALS, INCORPORATED MIRAMAR, FLORIDA REPORT IN5PECTION NO.:

99901215/91-01 RESULTS:

PAGE 3 of 3 associated with the FP&L purchases due to the fact that Mr. Werner recently (January 1991) purged all records dealing with FP&L from his files including the quality assurance manual.

3. Review of the Sale of Substituted John Crane Valve Packing to FP&L FP&L notified SMSI on August 29, 1990, thattheywouldnolongerbe doing business with them.

This decision was prompted by FP&L s discovery that SMSI had provided them with valve packing material other than what was specified on the purchase order.

FP&L stated that they ordered John Crane (JC) valve packing, s11e numbers K1760, C1050, and 1340, from SMSI and received, as a subst tute, packing that was not manufactured by JC but was packaged in a JC box. When asked about this, Mr. Werner admitted that he had, on several occasions, substituted different packing when he received an order from FP&L for JC packing.

He stated that he only did this when he did not have enough JC packing in stock to fulfill purchase order requirements.

He also stated that this happens all the time in this business and that the substitutions didn't really matter because he believed that all manufacturers of this type of packing produced products of similar quality. A review of SMSI invoices from other valve packing manufacturers revealed that SMSI also purchases packing from-Garlock Corporation and Chemstar Corporation.

FP&L aitially identified the problem at one of their fossil plants.

When they reviewed their records to determine the extent of the substituted packing at their other facilities, suspect material was identified in the warehouse for the Turkey Point nuclear facility. No suspect material was found at the St. Lucie nuclear facility and FP&L determined-that no suspect material had been installed in any nuclear unit. Samples of the suspect material found at Turkey Point were sent to JC for chemical-and braiding analysis. The results of the analysis verified that the suspect packing was not made from the material used by JC and was braided differently. JC's review also determined that SMSI was using non-standard boxes, cardboard spools instead of metal spools, and was remarking JC boxes and labels.

l After reviewing the few records available and after discussions with Mr. Werner, FP&L and FPC, the inspectors concluded that it was likely that SMSI has never sold any materials as safety-related to any nuclear utility and sold commercial-grade replacement materials to j

only FP&L and FPC among nuclear facilities.

B.

PERSONS CONTACTED:

C. E. Werner, President, SMSI 76

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MN 2 91991 Docket No. 99901131/88-01 Mr. T. Nightingale, President Voyten Electric and Electronics Post Office Box 361 Franklin, Pennsylvania 16323

Dear Mr. Nightingale:

This letter address the inspection of your f acility at Franklin, Pennsylvania, conducted by Mr. J. B. Jacobson of this office on October 31, 1988, and the discussions of his findings with you at the conclusion of the inspection.

Release of this report was delayed due to the NRC's ongoing review of nonconforming and substandard vendor products.

This inspection was conducted to review activities relative to your supply of electrical equipment to the nuclear industry and whether this equipment was properly represented. This inspection consisted of an examination of procedures and representative records, interviews with personnel, and observations by the inspector.

In accordance with 10 CFR 2.790 of the Comission's regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Room.

Should you have any questions concerning this inspection, we will be pleased to discuss them with you.

Sincerely, h/

Edward T. Baker, Acting Chief Vendor Inspection Branch Division of Reactor Inspection nd Safeguards Office of Nuclear Reactor Regulation

Enclosure:

Inspection Report 99901131/88-01 77

ORGANIZATION: VOYTEN ELECTRIC AND' ELECTRONICS FRANKLIN, PENNSYLVANIA REPORT <

INSPECTION INSFECTION NO.:

99901131/88-01 DATE:

10/31/88 ON-SITE HOURS:

'3' CORRESPONDENCE ADDRESS: Mr. T. Nightingale, President Voyten Electric and Electronics Post Office Box 361 Franklin, Pennsylvania 16323 ORGANIZATIONAL-CONTACT: Mr. Tom Nightingale TELEPHONE NUMBER:

(814) 432-5893 NUCLEAR INDUSTRY ACTIVITY:

Voyten Electric sells surplus circuit breakers, some of which may be used at nuclear plants.

ASSIGNED INSPECTOR:

k.k db 4

G*

B6 par-J. B. -Jacobson, Special Prbject Inspection Section ate (SPIS)

OTHER INSPECTOR (S):

APPROVED BY:

h af lN3b[BB-

' Gr ldis Potapovs Section Chief. ASPIS)

Date u

INSPECTION BASES AND SCOPE:

A.

-BASES:- 10 CFR Part 21.

B.-

SCOPE:- This inspection was conducted to determine whether Voyten Electric has ' sold refurbished circuit breakers.to the nuclear industry.

PLANT SITE APPLICABILITY: Braidwood (50-456/457), Robinson (50-261) 78

l ORGANIZATION:

V0YTEN ELECTRIC AND ELECTRONICS FRANKLIN, PENNSYLVANI A REPORT INSPECTION N0.: 99901131/88-01 RESULTS:

PAGE 2 of 3 A.

\\l0LAT10NS:

None.

B.

NONCONFORMANCES:

None.

C.

STATUS OF PREVIOUS INSPECTION FINDINGS:

None.

D.

OTHER FINDINGS AND COMMENTS:

1.

Customer Review This inspection was conducted as part of the NRC's effort to identify companies who are selling potentially refurbished molded case circuit breakers (MCCB's) to the nuclear industry.

In order to determine whether Voyten Electric had sold any refurbished cir-cuit breakers to the nuclear industry, a copy of the Voyten Electric Customer List was requested and obtained. This list contained the names and adoresses of all Voyten customers since 1983.

From review of the list it was determined that the only potential nuclear cus-tomer was Carolina Power and Light (CP&L). Vayten Electric was then asked for copies of all transactions with CP6L. The records reviewed inoicated that CP&L had made two purchases, one for a HKB2200W breaker for their Wilmington Division System Switc1 Room (P,0. No. 547598M, dated August 5,1984) and one for a TF136(90 breaker for nuclear e

plant construction (P.O. No. HBR 11563 da.ed December 26,1984).

No other nuclear orders were noted from the ;ustomer list review.

In addition to the customer list review, Voyten was asked if they remembered having shipped any breakers to a nuclear plant. Voyten remembered supplying two breakers to the Commonwealth Edison Braidwood Plant, purportedly for training purposes only. The breakers, a 500H P250 and a D5206 were supplied through Liberty Motor of Chicago, Illinois on January 2', 1986.

None of the orders reviewed appeared to be for safety-related applications and in none of the orders were any nuclear specific requirements invoked.

l l

79

ORGANIZATION:

V0YTEN ELECTRIC AND ELECTRONICS FRANKLIN, PENhSYLVANIA REPORT INSPECTION NO.: 99901131/88-01 RESULTS:

PAGE 3 of 3 2.-

Shop Review As part of the inspection a shop tour of the Voyten Electric facility was conducted. Observed during the tour were several molded case circuit breakers in various stages of disassembly and testing.

Upon discussion it was learned that Voyten Electric does refurbish molded case circuit breakers and that the breakers are often opened to facilitate cleaning or repair.

Part replace-ments were said to be accomplished by obtaining parts from other similar breakers.

In addition to the shop tour the inspector was shown several large rooms filled with surplus electrical equipment.

3.

Representation of Equipnent Sold During the inspection Voyten was asked whether equipment sold is specifically labeled as being new or as being reconditioned. The inspector was told that recently all reconditioned equipment is labeled as such, Review of the most recent CP&L purchase order

1. 547598M-AP confirmed that the shipping invoice did indicate the breaker-consisted of a new trip unit and a reconditioned frame.

E.

EXIT MEETING:

At the conclusion of the inspection an exit meeting was held with Mr.

T. Nightingale, President of Voyten Electric and Electronics.

j 80

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JAN 2 9 193I Docket No. 99901109/88-01 Mr. Kenneth Smith Branch Administrative Manager Westinghouse Electric Supply Company 64 Anthony Avenue Augusta, Maine 04330 s

Dear Mr. Smith:

This letter addresses the inspection of your f acility at Augusta, Maine, conducted by Mr. Stephen D. Alexunder of this office on July 24, 1988, and the discussions of his findings with you at the conclusion of the inspection.

Release of this report was delayed due to the NRC's ongoing review of nonconforming and substandard vendor products.

The inspection was conducted to obtain information un Westinghouse Electric Supply Company's (WESCO's) overall organization and operation, the origin of comercial-grade items sold to the Maine Yankee Atomic Power Plant, WESCO's handling of commercial-grade and nuclear safety-related material orders, and WESCO's sources of supply. This inspection consisted of an examination of representative records, interviews with personnel, and observations by the inspector.

in accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Room.

Should you have any questions concerning this inspection, we will be pleased tu discuss them with you.

Sincerely,

4 Ms Edward T. Eaker, Acting Chief Vendor Inspection Branch Division of Reactor Inspection and Safeguards Office of Nuclear Reactor Regulation

Enclosure:

Inspection Report No. 99901109/88-01

/

81

ORGANIZATION: WESTINGHOUSE ELECTRIC SUPPLY COMPANY AUGUSTA, MAINE REPORT INSPECTION INSPECTION NO : 99901109/88-01 DATE:

July 24, 1988 ON-SITE HOURS:

8 CORRESPONDENCE ADDRESS:

Westinghouse Electric Supply Company 64 Anthony Avenue Augusta, Maine 04330 I

ORGANIZATIONAL CONTACT:

Kenneth Smith, Branch Administrative Manager TELEPHONE NUMBER:

(207) 623-2546 NUCLEAR INDUSTRY ACTIVITY: Assigned as exclusive WESCO branch serving the Meine Yankee Atomic Power Plant for comercial grade materials. WESCO-Augusta refers Maine Yankee's nuclear safety-related orders to the Augusta Maine sales office of the Westinghouse Electric Corporation.

/f 6hl ASSIGNED INSPECTOR:

/

4 '-

Stephen D. Alexander, S~pecial Projects inspection Date Section, Vendor Inspection Branch, DRIS, NRR OTHER INSPECTOR (S):

Ric dPpintyre,SPIS,VIB,DRIS,NRR APPROVED BY:

SJ /LfAfd

( L '(3-Q bldisPotapovs, Chief,QpecialProjectsInspectionSection Date Vendor Inspection Branch Division of Reactor Inspection and Safeguards, NRR INSPECTION BASES AND SCOPE:

A.

BASES:

10 CFR Part 50, Appendix B and 10 CFR Pr.rt 21 B.

SCOPE: To obtain information on (1) WESCO system overall orgasitzation and operation, (2) origin / manufacturer of commercial grade items sold to the Maine Yankee Atomic Power Plant, (3) WESCO-Augusta handling of commercial grade and nuclear safety-related material orders, and (4)

WESCO-Augusta sources of supply.

PLANT SITE APPLICABILITY: Maine Yankee Atomic Power Plant (50-309).

82

-ORGANIZATION: WESTINGHOUSE ELECTRIC SUPPLY COMPANY AUGUSTA, MAINE REPORT INSPECTION NO : 99901109/88-01 RESULTS:

PAGE 2 of 4 A.

VIOLATIONS:

None.

B.

NONCONFORMANCES:

None.

C.

UNRESOLVED ITEMS:

None.

D.

STATUS OF PREVIOUS INSPECTION FINDINGS:

None.

' E.

OTHER FINDINGS AND C0KMENTS:

===1.

Background===

The Nuclear Regulatory Commission issued Information Notice (IN) 88-46 and its Supplement No. I to alert operators of nuclear power plants that surplus or refurbished molded case circuit breakers-(MCCBs)andotherelectricalequipment.havebeen supplied to several plants from certain companies in the Los Angeles area (named in the IN) either directly or through distributors, including various Westinghouse Electric Supply Company (WESCO) offices.

The concern is that many of the suspect MCCBs fraudulently represented as "new" were in fact refurbished.

Others repre-sented as new-or refurbished-have been found to be. refurbished with non-standard parts and in some cases with missing-parts, substandard parts, and shoddy workmanship. Some of these MCCBs i

have failed standard functional tests.

2.

Purpose The-purpose of this inspection at the WESCO location in Augusta Maine, which, according to its manager, is-the exclusive WESCO assigned to the Maine Yankee Atomic Power Plant, was_to determine, to the extent possible, what, if any,_ electrical equipment-from suspect sources known to have infiltrated the WESCO supply network has been supplied to Maine-Yankee by WESCO-Augusta.

83

ORGANIZATION: WESTINGHOUSE ELECTRIC SUPPLY COMPANY AUGUSTA, MAINE REPORT INSPECTION NO.:

99901109/88-01 RESULTS:

PAGE 3 of 4 3.

Review of Suppliers The inspectors met with Mr. Kenneth Smith, Branch Administrative Manager (BAM), on July 24, 1988 and informed him of the purpose of the visit and what records needed to be examined. The BAM h~i been given clearance from his management to cooperate as arranged just prior to the inspection by NRC headquarters.

The interview of the BAM began with his explanation of the WESCO system and WESCO-Augusta's relationship to Maine Yankee, other nuclear power plants, other WESCOs and to the local Westinghouse Electric Corporation sales office.

The inspectors then examined the entire general file of WESCO-Augusta's stock suppliers and found invoices from none of the companies suspected by the NRC of dealing in fraudulently referbished electrical equipment.

The inspectors learned that WESCO-Augusta does not stock the type of equipment described in IN 88-46. WESCO-Augusta's normal stock consists of common industrial electrical supplies used primarily by electrical distribution utilities, as opposed to power generation equipment.

All such material that may have been supplied to Maine Yankee would have to have been special ordered and all of the records of suppliers from which WESCO-Augusta ever special ordered non-stock material for Maine Yankee were said to be filed with the records of Maine Yankee purchases. The BAM stated that WESCO-Augusta can stecial order material, within certain guidelines from various ;ources according to lead time and availability.

In order of preference they incluoe:

(1) the manufacturer (Westinghouse), (2) other WESCOs (first within the same region or WESCO district and then anywhere in the WESCO system) and (3) outside the WESCO system.

The BAM further stated that WESCO-Augusta buys no material as nuclear safety-related. All purchases are stric.ly commercial grade.

4.

Review of Sales According to the BAM, WESCO is a wholly owned subsidiary of Westinghouse Electric Corporation, but operates as a separate

" profit center." He explained that under the WESCO system, WESCO-Augusta, like each of the other approximately 252 WESCO offices nationwide, is assigned as the the exclusive WESCO outlet I

l 84

l ORGANIZATION: WESTINGHOUSE ELECTRIC SUPPLY COMPANY AUGUSTA, MAINE REPORT INSPECTION NO.: 99901109/88-01 RESULTS:

PAGE 4 of 4 for certain nuclear plants (usually only the one closest) and does not supply any material directly to any nuclear plant except its assigned plant, Maine Yankee, a.

Nuclear Safety-Related Material - No such orders are accepted according to the BAM. The customer is referred for such orders to the local (also Augusta) Westinghouse Electric Corporation sales office or, with the customer's approval, the order is passed to that office. The inspectors' review of Maine Yankee procurements from WESCO-Augusta back through 1985 revealed no safety-related sales and no certificates of conformance were requested or provided.

b.

Commercial Grade Items - The inspectors' review of Maine Vinkee procurements back through 1985 indicated that the plant had bought a considerable quantity of commercial grade equipment from WESCO-Augusta. Material in the normal stock line was delivered from stock, but equipment and components of the type in question (primarily MCCBs) were special ordered from Westinghouse, other WESCOs and various independent suppliers and direct shipped to Maine Yankee.

The records of these sales included Maine Yankee purchase orders, WESCO-Augusta invoices, suppliers' invoices and shipping documents.

The inspectors' review of these records revealeo one instance in which WESCO-Augusta had obtained Federal Pacific Electric MCCBs for Maine Yankee from a company that had been implicated in the course of the NRC's investigation irto fraudulent or refurbished electrical components. These parti-cular MCCBs were later traced to nonsafety-related applications at the Maine Yankee Atomic Power Plant.

1 85

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JAN 2 91991 Docket No. 9991132/88-01 Mr. C. Antonikas, Branch Manager Westinghouse Electric Supply Company Post Office Box 607 Murraysville, Pennsylvania 15688

Dear Mr. Antonikas:

This letter addresses the inspection of your facility at Murraysville, Pennsylvania, conducted by Messrs. J. Jacobson and J. Knox of this office on September 14, 1988, and the discussions of their findings with you and other members of your staff at the conclusion of the inspection.

Release of this report was delayed due to the NRC's ongoing review of nonconforming and substandard vendor products.

The inspection was condacted to review activities relative to your supply of molded case circuit breakers to Westinghouse Nuclear Services Division for subsequent dedication and sale to the nuclear industry.

This inspection consisted of an examination of procedures and representative records, interviews with personnel, and observations by the inspectors, in accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Occument Room.

Should you have questions concerning this inspection, we will be pleased to discuss them with you.

Since rely,

/"

~

Edwarc T.

aker, Acting Chief Vendor Inspection Branch Division of Reactor Inspection and Safeguards Office of Nuclear Reactor Regulation

Enclosure:

Inspection Report 99901132/88-01 l

l 86

ORGANIZATION.

WESTINGHOUSE ELECTRIC SUPPLY COMPANY MURRAYSVILLE, PENNSYLVANIA REPORT INSPECTION INSPECTION NO.: 99901132/88 01 DATE:

9/14/88 ON-SITE HOURS: 8 CORRESPONDENCE ADDRESS:

Westinghouse Electric Supply Company Mr. C. Antonikas, Branch Manager Post Office Box 607 Murraysville, Pennsylvania 15668 ORGANIZAT10fiAL CONTACT: Cris Antonikas TELEPHONE NUMBER:

(412) 733-6800 NUCLEAR INDUSTRY ACT;VITY: Westinghouse Electric Supply Company (WESCO)

Murraysville supplies safety-related relays and other comercial grade com-ponents to Westinghouse Nuclear Service Division (fiSD) for sale to the nuclear industry.

/

ASSIGNED !!4SPECTOR:

c/ m'L

/2/fdf

/

T, (obson, S (fate Section(SPIS)pecialProjectsInspection OTHERIf4SPECTOR(S):

J. Knox, SPIS APPROVED BY: /

M u /_ -

/

/

. Potap M, Section Chief. SPIS ate INSPECTION BASES AND SCOPE:

A.

BASES:

10 CFR Part 21 and Appendix B to 10 CFR Part 50.

B.

SCOPE:

This limited inspection was conducted to review activities relaied to WESCO's supply of molded case circuit breakers.to Westinghouse NSD for subsequent dedication.

PLANT SITE APPLICABILITY:

All nuclear facilities using Westinghouse molded case circuit breakers.

87

ORGANIZATION: WESTINGHOUSE ELECTRIC SUPPLY COMPMAY MURRAYSVILLE, PENNSYLVANNIA l

REPORT INSPECTION NO.: 99901132/88 01 RESULTS:

PAGE 7 of 3 i

?

A.

VIOLATION:

None B.

NONCONFORMANCE:

None 1

C.

STATUS OF PREVIOUS INSPECTION FINDINGS:

None D.

OTHER FINDINGS AND COMMENTS:

During the inspection, a review was conducted of the WESCO, Murraysville activities relative to their supply of commercial grade molded case t

circuit breakers to Westinghouse NSD.

Over the last three years WESCO 4

Murraysville has supplied approximately 200 molded case circuit breakers to the Westinghouse NSD dedication program. Of particular concein was where WESCO obtained the breakers sold to Westinghouse NSD. Recent information has alerted the NRC to a large supply of refurbished molded case circuit breakers th tt_have infiltrated the i

commercial marketplace (detailed in NRC Information Notice 88-46).

At the time of the inspection, WESCO was already in the process of determining their supply sources for the 200 breakers and had completed their record review for the 65 most recent orders. All of the orders reviewed had been supplied by the Westinghouse business-unit that f

ma.;U actures the type of breakers in question.

In addition, the-NRC inspectors reviewed a sample of the orders and confirmed they had 4

indeed been supplied by-the Westinghouse business unit.

When WESCO was questioned as to where else they procure breakers, the inspectors were told that if the breakers were unavailable from the business unit, WESCO might go to another WESCO office or outside-the Westinghouse Corporation to obtain the breakers.

However, WESCO stated that they could not remember ever having to do this for any of the

- breakers supplied to Westinghouse NSD.

In addition, to the above review, the NRC inspectors reviewed the WESCO financial records for payments to suppliers for. 1986, 1987, and-1988.

Several of the suspected-circuit breaker refurbishers appeared on the-list and in fact had supplied circuit breakers to WESCO Murraysville over this time period.

Each of the orders originating from the suspect companies were' tracked and found to have been supplied to non-nuclear customers.

1 88

-.... u.

- ~..

ORGANIZATION: WESTINGHOUSE ELECTRIC SUPPLY COMPMAY i

MURRAY$VILLE, PENNSYLVANNIA i

REPORT INSPECTION k0.:

99901132/88-01 RESULTS:

PAGE 3 of 3 A review of the material currently in stock at the WESCO warehouse i

revealed that the five samples for which records were requested.

all had originated from the Westinghouse business unit.

In summary the NRC review detennined that currently no procedures are in place that would prevent WESCO Murraysville from supplying Westinghouse NSD with breakers from other WESCOs or from sources outside the Westinghouse Cor) oration. However, the review conducted determined that for the brea cers previously sold to Westinghouse NSD, reasonable assurance exists that the breakers originated from the-Westinghouse business unit as new and were not refurbished material.

Should Westinghouse NSD continue to procure commercial grade molded case circuit breakers from WESCO Murraysville, procedures would need to be implenented to ensure that only new Westinghouse breakers are supplied.

E.

PERSONS CONTACTED:

C. Antonikas, Branch Manager K. Gordan, Branch Administrative Manager S. Cunningham, Westinghouse Electric, Monroeville i

i r

89 i

I Selected Dulletins and Information Notices Concerning Adequacy of Vendor Audits and Quality of Vendor Products 1.fifLVE.Q 111L1 1.

Information Notice 90-43 Mechanical Interfurence Supplement 1 With Thermal Trip Function in GE Molded-Case Circuit Dreakers 2.

Information Notice 91-01 Supplier of Misrepresented Resistors 3.

Information Notice 91-07 Maintenance Deficiency Associated With General Electric Horizontal Custom 8000 Induction Motors 4

Information Notice 91-09 Counterfeiting of Crane Valves 5.

Information Notice 91-15 Incorrect Configuration of Dreaker Operating Springs in General Electric AK-Series Metal-Clad Circuit Dreakers 6.

Information Notice 91-21 Inadequate Quality Assurance Program of Vendor Supplying Safety-Related Equipment 90

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